Responding to Anna Washington's Complaint below:

• Assume that you represent the defendant in the car accident case filed by Anna Washington. Your client contends that, while he was in a car accident with Anna, he was not texting at the time. He says he had a seizure that caused him to momentarily black out and hit her car. That is the basis for his defense.
• Respond directly to each numbered paragraph of the Complaint you receive.
• Add affirmative defenses to the end of the Answer.

COMPLAINT

Comes now the Plaintiff, by counsel,Anna Washington, and by way of Complaint against the Defendant herein, hereby allege and states as follows:

1. Plaintiff, David Carver, has been at all times relevant hereto, and continue to remain, an adult over eighteen (18) years of age and legal and bonafide resident of 10 Elm Street, of the City of Scottsburg, County of Scott, State of Indiana.
2. At the aforesaid time and place, the Defendant, David Carver, worked at Amazon at said time of this accident as he was on his way to work. Defendant Carver worked at Amazon in Scottsburg, Indiana.
3. At the aforesaid time and place the Defendant herein, David Carver, did carelessly and negligently rear end plaintiff Anna Washington when stopping at a red light while looking on his phone on his way to work. The accident occurred on October 23^rd, 2022 at the corner of Elm and Main Street in Scottsburg, Indiana.
4. During that time, Anna Washington was on her way to Pick her son up from Scottsburg Middle School. At 2:00pm experienced a loud sound and a movement in her car while stopping at a stop light when she noticed that David Carter had rear ended her while being on his phone. Anna Washington immediately called 911 from her sudden pain and car damage.
5. Upon hospitalization, plaintiff Washington suffered whiplash and other soft tissue damage. Subsequent testing indicated that the loss of functionality was due to the effects of the car accident with defendant Carver. Within the next week, Washington had 3 doctors' appointments after being released from hospitalization of 3 days. The afore-described accident resulted as a direct and proximate cause of the negligence of the Defendant herein, David Carver, said negligence, breach of duty, and causation consisting of, but not being limited to, the following:

1. Failure to maintain a proper look out;
2. Failure to keep attention on driving;
3. Failure to maintain proper cellphone use while operating a vehicle; and
4. Failure to stop at a reasonable distance.

1. The aforesaid negligence, breach of duty, and causation of the Defendant, David Carver, proximately caused injury, damage, and loss to the plaintiff, Anna Washington, including, but not limited to, the following:
2. Past and future medical expenses;
3. Past and future related expenses;
4. Past and future attorney fees;
5. Lost time due to injuries;
6. Diminishment of future income earning ability; and
7. Severe physical pain and suffering and loss of enjoyment of life.

WHEREFORE, Plaintiff Anna Washington demands judgment against defendant David Carver, in the total amount of $50,000, to compensate it for the pain, suffering and property damage of the vehicle, as well as for interest, costs and attorneys' fees incurred in bringing this action to resolution.