fars# 450884

FARS 450884

rosahowell
B6

of 2 FAFS Encyclopedia

2003 Fatality Analysis Reporting System ACCIDENT LEVEL

US Dqmlmll d T m m t amp U f m d ~ T n l R c S d d y Acbldrwdkm

9999-Unknown

10-Local Road 01 Street trattlS-Unkncwn urban

3-Dark but Lighted

Ol-Fm-tPFampar OndUQs amp-End) 0 2 - F ~ t o F m t Ondudes Head-on) 03-FmtPSidS Same Direction lO-Rear4c-Rear

ll-Other(End Swipe3 and

99-Unknown toSidrUnpCLHrsdion Not

NOKINTERCWHOE INTERCHANGE ARE4 lO-lnteRamplia 11-lnlBrsBClim Related 12-Driveway -ea

15-Olher Locam In Interchange

M D r h W V rUr 8tC Z-Entrrnce~Exit Ramp Related 05-EnlramampxB Ramp Wted 14-Cr016~er-ReWed OSRd G d - M

httpwww-fars nhtsadotgovQue~Too~Que~Sectio~AccidentDisplayFormaspxSho 10272010

FARS Encyclopedia Page 2 of 2

I ___

NUMBER OF TRAVEL LANES I I

J7Sevsn 01 More Lams Unknown I

-farsnhtsadotgovQueryTooVQuerySectio~Acciden~isplayFo~aspxSho 1 02720 1 0


2003 Fatality Analysis Reporting System Q VEHICLE LEVEL US Dgrrmtdlm- HamdHphorlTrampSllaty 1Bdwdlm

99-Unknown WMilitaw Vehicle

WTH OTHER VEHICLE

de (Comprbnent Intrusion Unknown)

MTruclTraampr(a) 80-Passenp8r Car (only when

00-Not Applicable Nota

01-VaruEnclosed Box

086rain Chips Gravel

2 0 ~ (seats 9-15 people including d w r ) 21-Bus (seats more than 15 peopklduding

MedlHcavy TruckIBus OQ-POk

httpwww-far n h t s a d o t g o v Q u e r y T o o Y Q 10272010


SS-Unknorm

Heavy TNCk or Bus Other Carp0 (not codes 01-09 20-21) avy TNCk or Bus Unkn Cargo Ruhl Turn on R W

Men0 Staled) driver BMher AvoidanceManewer

ampNo1 Reported I Inwndusive (by police)

an Amculalad Vehi

httpwww-fars n h t s a d o t g o v Q u e r y T o o V Q a s p x S h o w 10272010

FARS 480273

CAUSE NO 200600134

JENNIFER JARMON and 0 IN THE DISIWCT COURT OF CASSNS JARMON Individually And As Co-Administrators of THE ESTAE OF 5 CASSIDY JARMON Deceased and as 5 Next Friends to C W I E JARMON sect A Minor Child P

0 V sect JOHNSON COUNTY TEXAS

5 DELBERT J DAVJDSON 0 DATMtER CHRYSLER CORPORATION sect and DAIMLER CHRYSER COMPANY LLC 8 413m JUDICIAL DISTRICT

PLAINTIFFSrsquo SECOND AMENDED ORIGIN AL PETITION

TO THE H O N O U B U JUDGE OF SAID COURT

COME NOW Plaintiffs Jennifer Jarmon and Cassius Jarmon Individually and as Co-

Administrators of Tbe Estate of Cassidy Jarmon Deceased and as Next Friends to Callie

Jarmon a minor child in the above styled and numbered cause of action and file this their

Second Amended Original Petition complaining of Defendant Delbert J Davidson (hereafter

ldquoDavidsonrdquo) Daimler Chrysler Corporation and Daimler Chrysler Company LLC (hereafter

collectively ldquoDCrdquo) and for cause thedore would respectfully show this honorable Court the

following

1 LEVEL 3 DISCOVERY CONTROL PLAN BY COURT ORDER

1 Pursuant to Rule 1901 TM R CIV P Plaintiffs allege that this case is one which

wiU require a discovery control plan tailored to the cvcumstances of the case The Court has

en- a discovery control plan pursuant to Level 3 Rule 1904 TEX R CIV P

II lampKmS

2 Plaintiffs Jennifer and Casius Jamon are individuals residing in Clebume

Johnson County Texas

3 Defendant Demert J Davidson is an individual residing in Johnson County

Texas and has already made au appearance in this case No service is necessary at this time

4 Defendant Daimler Chrysler Corporation is a Miclugan corporation and is

authorized to do business in the State of Texas Process was previously served upon DCC by

serving its registered agent CT Corporation Systems of Dallas Texas Defendant Daimler

Chryslcr Company LLC has entered an appearance in this case as the successor to Daimler

Chrysler Corporation by conversion effective March 31 2007 Dmder Chrysler Corporation

was the successor to Chrysler Corporation by merger in 1998

rIL JURISDICTION VENUE AND STANDING

5 Jurisdiction is proper in the District Court as the amount in contmversy greatly

exceeds the minimal jurisdictional limits of this Court and is within tk maximum jurisdictional

limits of any other state court in Johnson County Texas

6 Venue i s proper in Johnson County pursuant to ~15002(a)(l) and (2) TM CIV

PRAC ampREM CODE in that the event giving rise to this case occurred in Johnson County Texas

and Defendant Davldson resided in Johnson County Texas at the time of the event complained

of Venue is proper as to the remaining Defendants pursuant to 515005 TEX Crv PRAC ampREM

CODE

2

Iv STATUS OF DEFJ3NDANTS

7 At all times material heramp Defendant DC was engaged in the business of

designing manufacturing marketing and distributing automobiles including the vehicle made

the subject of this lawsuit for sale to and for use by members of the general public

V uC2-s

8 On or about February 12 2006 Jennifer Jarmon was operating her 1993 Jeep

Gxand Cherokee Vehicle Identification Number lJ4GZ58S6DC640210 (rhe subject vehicle)

manufactured by DeFendant DC Also in che vehicle were Jennifer and Cassius Jarrnonrsquos two

children Cassidy Jarmon and Calk Jarmon At that time and on that occasion the Jarmon

vehicle was struck in the rear by a 2001 Chevrolet Lumina 4-door sedan being operated by

Jhfendant Davidson Following the impact the Jarmon vehicle came to rest on the road way

and due to a leaking fuel system component a fuel-fed fire immediately began at the tear of the

Jeep Grand Cherokee Although Cassidy Jannoa survived the impact due to the fire that erupted

because of a defective fuel tank in the Jeep vehicle Cassidy was trapped in the second seat of the

Jeep and could not be rescued from the vehicle Flames from the pst-collision fuel-fed fire

entered into the passenger compartment of the Jeep and wed injury to Jennifer J m o n Wie

Jarmon and caused smoke inhalation and thermal injuries to Cassidy Jarmon resulting in her

death

9 Plaintiffs would show that at all times they have performed all conditions

precedent to brin~g this lawsuit and to recover under the various causes of action stated

herein

3

10 At ail material times plaintiffs would show that wherein i t is alleged that

Defendants did did not andor failed to act it may be shown that Defendants acted individually

andor by and through M y authorized employees servants agents andor officers Plaintiffs

would furthex show that at all times material hereto these persons were expressly authorized to

so act or alternatively were acting within the apparent authority andor authority necessarily

implied in order for the agents to perform and exercise the authority expresdy granted Plaintiffs

further allege respondeut superior liability

11 Xn the further alternative and without waiver of the foregoing if ir be shown that

persons purporting to act on Defendantsrsquo behalf as alleged were not so auzhorized then

Defendants have in all things ratified the actions or inactions of those persons and have accepted

the benefits thereof

12 Further in the design markering and distribution of the Jeep Grand Cherokee

the Plaintiffs would show that decisions with regard to the placement of the fuel tank failure to

adequately guard or shieid the fuel tank and in testing and evaluaring the function of the vehicle

fuel rank those agents and employees of Defendant DC were acting in their capacity as vice-

principals

n CAUSES OF ACTION

k Neeligenceo f Defendant Davidson

13 The injuries and damages suffered by the Plantiffs and the death of Cassidy

Jarmon were proximately caused by the negligence of Defendant Davidson in operaring the 200 1

Chevrvlet Lumina at the rime of Ihe OccUrreIlce in question in

a failing to keep a proper lookout to avoid the collision in question

4

b failing to turn his vehicle in a timely manner to avoid the mKsion in question

aud

failing to timely and properly apply his brakes to avoid the collision in question c

a peeelisence of Defendant Rc

14 The injuries and damages suffered by the Phintiffs and the death of Cassidy

Jamon were proximately caused by the negligence of Dcfendant DC in designing testing

assembling supplying and distributing the 1993 Jeep Grand Cherokee sport utility vehicIe

including but not lirmted to the following particulars

a In failing to design the vehicle fuel supply system to be crashworthy

b In fading to design the vehicle in such manner that gasoline would not escape from

the fuel supply systun in the event of foreseeable collisions

c In failing to construct the fuel supply system so that it would contain fuel in the event

of foreseeable collisions

d lo failing to design the fuel supply system in such a manner so 8 to prevent post-

collision fuel fed fins

e In failing to properly test and evaluate the vehicle

f In failing to properly guard or shield the vehiclersquos fuel tmk and delivery system

g In the placement and packaging of the vehiclersquos fuel tamk and fuel supply system

h In its design of the fuel supply system in positioning the vehiclersquos fuel tank at a

location on the vehicle that subjected it to hazards associated with the environment in

which it was located

i In designing the fuel supply system such that the vehiclersquos tank was inadequately

protected fromenvironmenral hazards in on and about its surrounding tank

5

j Failing to warn of dangers associated with the design ofthe fuel supply system and its

position on the vehicle

k In it design of the fuel supply system in an uncrashworthy manner

I Failing ul conduct adequate testing of the design of the fuel supply system for the

subject vehick

m In failing to warn of the inadequate testing of the design of the fuel supply system for

the subject vehicle

n Failing to provide adequate warnings to the public in general and to these

Plaintiffs and deceased specifically of the dargerous propensities of the flawed design

of the fuel supply system on the subject vehicle

0 In acting to conceal defects and dangers in its products from the public from injured

persons and governmental entities rather than fulfilling its common law and statutory

obligations to provide adequate warnings and to remedy such defects

p In continuing to deign market and sell this line of sport utility vehicles without

substantial change after receiving sufficient knowledge as to the nature of the defects

and the danger to the public

q In rbe design of the subject vehicle which failed to correct serious rear structure

design deficiencies in location mounting and protection of the fuel tank from

environmental hazards

r In the design of the subjcct vehicle which failed to restrict foreseeable f m from

rapidly entering into the occupant compartment of the vehicle thus limiting the timely

rescue of accident victims

6

s In failmg to provide adequate warnings concerning the rear strucrurd cnsh

perfopmaow of the vehicle when fitted with a trailer two hitch

t In failing to design the vehicle in such a manner that the rear structure was

crashworthy when fitted with a trailer hitamp

u In failing to design the rear structure of the vehicle in such a manner that the vehicle

would be crashworthy in rear impacts

v In failing to design the vehicle with adequate rear under-ride protection in the event

of a rear crash and

w In designing rhe fuel tank for the vehicle in such a manner that it was dangerously

exposed to impacts and was not adequately protected within structure of the vehicle

C mitt L i i i t v of Men dant DC

15 Plaintiffs further allege that the 1993 Jeep Grand Cherokee sport utility vehicle

was defective and unsafe for its intended purposes at the time of its design by Defendant DC and

its sale mcVor transfer into the stream of commerce and that at the time Plaintiffs Jennifer

Jarmon and Casius Jannon took possession of the vehicle The 1993 Jeep Grand Cherokee

spxt utility vehicle was in substantially the same condition at the time of the collision involved

in this suit as when it was manufactured and distributed by Defendant DC The Plaintiffs wodd

further show rhat there were safer alternative designs far the subject vehicle fuel containment

system pursuant to 582005(a) and (b) TEX Crv PRAC amp REM CODE The product was

defectively designed and unmsonably dangerous to Plainriffs in that the design of the vehicle

made it unsafe for the following reasons


7

b Xn failing to design the vehicle in such manner that gasoline would not escape from

the fuel supply system in the event of foreseeable collisions



d In failing to design the fuel suppIy system in such a manner so as to prevent post-

collision fuel fed fms

e Xn failing to properly test amdevaluate the vehicle

f In failing to properly guard or shield the vehiclersquos fuel tank and delivery system

g In the placcmcnt and packaging of the vehiclersquos fuel tank and fuel supply system

h h its design of the fuel supply system in positioning the vehiclersquos fuel tank at a




protected from environmental hazards in on and about its surrounding tank

j Failig to wam of dangers associated with the design of the fuel supply system and its


k In it design of the fuel supply system in an uncrashwoahy manner

1 Failing to conduct adequate testing of the design of the fuel supply system for the

subject vehcle

m In failing to warn of the inadequate testkg of the design of the fuel supply system for

the subject vehicle

n Failing to provide adequate warnings to thc public in general and to these

8

Plaintiffs and deceased specifically of the dangerous propensities of the flawed design





p In continuing to design market and sell this line of sport utility vehicles without

Substantial change after receiving sufficienr knowledge as to the nature of the defects


q In the design of the subject vehicle which failed to correct serious rear structure

design deficiencies in location mounting and proWion of the fuel tank from


r In the design of the subject vehicle which failed to restrict foreseeable fires from



s In failing to provide adequate warnings concerning the rear structural crash

performance of the vehicle when fitted with a trailer two hitch


ciashworthy when fitted with a trailer bitch



V In failing to design the vehicle with adequate rear under-ride protection in the event

of a rear crash and

9

w In designing the fuel tank for the vehicle in such a manner that it was dansrously

exposed to impacts and was not adequately protected within structme of the vehicle

16 Plaintiffs further allege that such defects in the design of the vehicle were a

producing cause of the death of Cassidy Jannon and the injuries and damages sustained by

Plaintiffs

D Breaamp of Imnlied Warrantv of Merchantability

17 The vehicle in question is a good for purposes of Ihe TEX BUS ampCorn CODE

and Defendant JX was a merchant with respect to goods of that kind Defendant DC breached

the implied warranty of merchantability set forth in TEX Bus amp COMM CODE $2314 by

selling amphe vehicle in question when i t was defective that is not fit for the ordinary purposes for

whichsuch goods are used because of the and crashwonhiness deficiencies described more fully

herein Such breach of warranty was a proximare cause of the injuries and damages to Plaintiffs

E lh-eaeh of Warranh of I3 tness for Particular Punmse

18 Defendant DC impliedly warranted to the public generally and specifically to

Plaintiffs that the 1993 Yecp Grand Cherokee was fit for che particular purpose for which the

vehicle was intended Defendant DC at the time of rhe design manufacm and sale of the

vehicle had reason to know of the particular purpose for which the vehicle and its fuel supply

system were required The Plaintiffs relied upon Defendant Ws skill and judgment to selea

and hrnish suitable goods and components The vehicle in question was unfit for the p w s e

for which it was intended to be used in one or more of the following particulars

a In failing to design the vehicle kuel supply s y s m to be crashworthy

b In failing tD design the vehicle in such manner that gasoline would not escape from

tbe fuel supply system in the event of foreseeable collisions

IO


d In failing to design the fuel supply system in such a manner so as to prevent post-

collision fuel fed fires


f h fding to properly guard or shield the vehiclersquos fuel tank and delivery system

g In the placement and packaging of the vehiclersquos fuel tank and fuel supply system


locarion on the vehicle that subjected it to hazards associated with the mvironment in

which it was locaLed



j Failing to warn of dangers associated with the design of the fuel supply system and its


k In it design of the fuel supply system in an uncrasbworthy manner


subject vehicle

m In Failing to warn of the inadequate testing of the design of the fuel supply system for

the subject vehicle


Plaintiffs and deceaKd specifically of the dangexous propensities of the flawed design


11


persons and governmental entities rather than fulfdling its cnmmon law and statutory

obligatiom to provide adequate warnings and to remedy such defects

p In continuing to ampsign market and selI this line of sport utility vehicles without

substantial change atkr receiving sufficient knowledge as to the name of the defects


q In the design of rhe subject vehicle which failed to correct serious rear structure

design deficiencies in Iccation mounting and protection of the fuel tank from


r In the design of the subject vehicle which failed to resuict foremable fires from



s In failing to provide adequate warnings concerning the rear s t r u c d crash

perfomance of the vehicle when fitted with a traik two hitch

t In fa i l i i to design the vehicle in such a manner that the rear structure was

crashworthy when fitted with a tniler hitch

u In failing to design the rear structure of rhe vehicle in such a manner that the vehicle



of a rear crash and

w In designing the fuel tank for the vehicle in such a manner that it was dangerously

exposed to impacts and WBS not adequately protected wirhin structure of the vehicle

12

r

19 Plaintiffs suffered injuries and damages as set forth hereafter as a proximate result

of the breach of this warranty

F ampampreDreSeIlbtiwShiCt Liability Of Defendant DC

20 Plaintiffs allege that Defendant DC was in the business of marketing and selling

automobiles and made misrepresentations to the public of material facts concerning the character

andor quality of the veh~le that i s the subject of this lawsuit Purchasers of the vehicle

justifiably relied upon these misrepresentations that induced and influenced them to purchase and

transport others in the Jeep Grand Cherokee sport utility vehicle including the vehicle in

question As a result Plaintiffs sustained severe traumatic debilitating injuries during the

incident and Cassidy Jannon lost her life Plaintiffs therefore invoke the DoctrinP of Strict

Liability contained in Section 402B of the R E S T A rdquo T (2ND) OF TORTS Furthermore

Plaintiffs allege that these misrepresentations o f material fact were a producing cause of the

injuries and damages sustained by Plaintiffs Defendant DC misrepresented its product as being

safe in spite of the following defects


b In failing to design the vehicle in such manner that gasoline would not escape from

rhe fuel supply system in the event of foreseeable collisions

c In failing to wnstmct the fuel supply system so that it would contain fuel in the event

of fomeeable collisions

d In failing to design the fuel supply system in such a manner so a$ to prevent post-


e Xn failing to properly twt and evaluate the vehicle

f ln failing to properly guard or shield the vehiclersquos fuel tank and delivery system

13

g In the placement and packaging of the vehiclersquos fuel rank and Fuel supply system

h In its design of the fuei supply system in positioning the vehiclersquos fuel tank at a





j Failing to wam of dangers associated with the design of the fuel supply systemand it$


k In i t design of the fuel supply system in an uncrashworthy manner


subjecr vehicle


the Subject vehicle


Plaintiffs and deceased specifcally of the dangerous propensities of the flawed design


0 In acting to conceal defects and daugers in its products from the public from injured

persons and governmental entities rather than fulfilling its common law and sta~tory





14

q In the design of the subjcct vehicle which failed to correct serious rear structure

design deficiencies in location rnounhnamp and protection of the fuel tank from

envixonmental hazards

r In the design of the subject vehicle which failed to restrict foreseeable fues from

rapidly entering into tk occupant compartment of rhe vehicle thus limiting the timely





crashworthy when fitted with a trailer hitch

u In failing to ampsign the mar structure of the vehicle in such a manner that the vehicle

would be crashworthy in rear impacrs


of a fear crash and

w In designing the fuel tank for Ihe vehicle in such a manner that it was dangerously

exposed to impacts and was not adequately protected within s t r u c m of the vehicle

G Joint and Several L iability

21 Plaintiffs would further show this honorable Court and jury that each and all of

the foregoing acts and omissions taken singularly or in combination with the other were the

proximate andor producing cause of the death of Cassidy Jarmon and the injuries and damages

suffered by Plaintiffs Therefore Plaintiffs complain of Refendam jointly and severally

15

VII SURVIVAL ACTION - 871021 et s e a TEX CIV FC amp ]REM CODE

22 Plaintiffs Jennifer Jarmon and Cassius Jarmon Individually and as Co-

Administrators of the Estate of Cassidy Jarmon SUE pursuant to $71021 er seq TEX C1V PRAC

amp REM CODE for Defendants negligence and strict liability in tort misrepresentations and

breach of warranty which were a proximatepducing cause of the injuries and damages

sustained by Cassidy Jamon prior ta her death as well as for all other damages allowed by law

including the following elements in an amount within the jurisdictional limits ofthis Court

a The reasonable and customary expenses for autopsy funeral and burial for

decedent

Reasonable and necessary hospital and medical expenses

Physical pain agony and suffering experienced by decedent and

Mental anguish and suffering including the fear and d i s k s associated with

imminent death

b

c

d

m WRONGFUL DEATH - S 71001 ct SW TEX CIV PRAC amp REM CODE

23 In addition to the other legal bases previously pleaded herein this action is

bmght by Plaintiffs Jennifer Jarmon and Cassius J m o n Individually as statutou beneficiaries

Of Cassidy armo on pursuant to $71001 et seq O f the TEX CN PRAC ampREM CODE commonly

referred to as the Wronl Death Act on behalf of statutory beneficimks of Cassidy Jarmon

pursumt to $71004 TEX CIV h A C amp REM CODE for damages sustained by Plaintiffs of which

the negligence and strict liability in ton of Defendants was a producingproximte cause

16

Plaintiffs should be compensated in an mount in excess of the jurisdictional limits of this Court

considering the following elements of damages

a Pecuniary loss includmg loss of care maintenance support services advice

counsel and reasonable contributions of a pecuniary value that Piaintjffs Jennifer

and Cassius Jarmon Individually and as Cc-Administrators of the Estate of

Cassidy Jannon aud as Next Friends of Callie Jarmon a minor child would in

reasonable probability have received from the decedent Cassidy Jamon had she

lived

Loss of Companionship and society including the loss of the positive benefits

flowing from the love comfort affmion companionship and society that

Plaintiffs Jennifer and Cassius Jarmon Individually and as Co-Adrmnistraton of

the Estate of Cassidy Jarmon and as Next Friends of Callie Jarmon a minor

child would in reasonable probability have received from the decedent Cassidy

Jarmon had she lived

Mental depression and mental anguish and

Reasonable and necessary expenses associated with autopsy funeral and burial

b

c

d

Ix DAMAGES

24 As a result of the injuries to and death of Cassidy Jarmon Deceased as herein set

out Plaintiffs Jennifer and Cassius J-n Individually and 8s Co-Administrators of the Estate

of Cassidy Jarmon and as Nexr Friends of Callie Jarmon a nunor child are entitled to the

recovery of survival and wrongful death dam- including but not limited to the following

a

b

The reasonable and customary funeral and burial expenses for decedent

Physical pain agony and suffering and

17

c Mental ma- and suffering iocluding the fear a d distress associated with

imminent death

As a result of thc injuries to and death of Cassidy Jarmon BS herein set out

Plaintiffs Jennifer and Cassius Jarmon Individually and ag Co-Administrators of the Estate of

Cassidy Jarmon and as Next Friends of Cal)ie Jarmon a minor child are entitled to the recovery

of survival and wrongful death damages including but not limited to the following

25

a Mental anguish grief sorrow emotional pain torment and suffering experienced

by Plaintiffs Jennifer and Cassius Jmon Individually and as Co-Administrators

of the Estate of Cassidy Jarman and as Next Friends of Callie Jarmon a minor

child in the past associated with the loss ofthe decedent

Mental anguish mental depression Nef m o w emotional pain torment and

suffering experienced by Plaintiffs Jennifer and Cassius Jarmon Individually and

as Co-Administrators of the Estate of Cassidy Jarmon and as Next Friends of

Callie J m o n a minor child which in all rrasonable probability will continue in

the future

Loss of consortium and sociery in the past

Loss of consortium and society which in all reasonable probability will continue

in the future

Loss of pecuniary benefits in the past and

Loss of pecuniary benefits which in all reasonable probability will continue in

the future

b

c

d

e

f

18

X PERSONAL INJUR Y DAM4 GES TO CALLIE JARMON

26 Plaintiffs Jennifer and Cassius Jarmon as Next Priends of Callie Jarmon a minor

child would show that as a proximatelproducing result of the conduct of the Defendants both in

nedigcnce and strict liability Callie Jarmon sustained severe permanent disability and

disfiguring injuries which have caused her damage and in reasonable probability will continue

to cause her damages for the remainder of her natural life As a result of those injuries Plaintiffs

should be compensated considering the following elements of damage

a

b

C

d

e

f

0 C1

h

i

j

Pain suffering and mental anguish in the past

Pain suffering and mental anguish which in reasonable probability she will

sustain in the future

Past medical hospital surgical and rehabilitative expenses

Medical hospital surgical and rehabilitative expenses which in reasonabIe

probability she will sustain in the future

Disfiwment in the past

Disfigurement which in reasonable probability she will sustain in the future

Physical impairment in the past

Physical impairment which is reasonably probable that she will suffer in the

future

Last earnings and earning capacity which in reasonable probability she will

sustain in the future after her eighteenth birthday and

ReasonabIe and necessary costs for anendant care which in reasonable

probability she will require in the futum

19

XI DIRECT PERSONAL IN0 RY DAMAGES TO JENNIFER JARMON AND

BYSTANDER CLAIMS OF JENNIFER JARMON ANI CA SSKS JARMON

27 As a direct and proximare result of the Defendants negligence as above

described Plaintiff Jennifer Jannon sustained severe personal injuries which she will endure in

the future Additionally Jennifer Jarmon and Cassius Jarmon suffered severe mental pain and

suffering since the perception of the occurrence made the basis of this suit and of the injuries and

harm sustained by their daughhters Cassidy Jarmon and Callie Jarmon In particular Plaintiffs

will show that immediately afm the occurrence made the basis of this suit they have

experienced extreme nervousness distractibility physical illness difficulty sleeping difficulty

concentrating and fear They have incurred and will continue to incur reasonable and necessary

expenses for medical care and treatment of these conditions Plaintiffs sue for a sum within the

jurisdictional limits of this Court for these injuries

XLL EXEhWLARY DAMAGJIS

28 In addition to and including the above Plaintiffs would show this honorable Court

and the jury that the acts practices and omissions of Defendant DC constitute clear and

convincing evidence as dehed by 841001 of the Texas Civil Practice and Remedies Code of

gross negligence on the part of Defendant in that such acts practices andor omissions a) when

viewed objectively from the standpoint of the Defendant at the time of its occurrence involved an

e x w m degree of risk considering the probability and magnitude of the potential harm to others

and b) of which the Defendant had actual subjective awareness of the risks involved but

nevertheless proceeded with conscious indiffexence to the rights safety or welfare of others

including Plaintiffs and Cassidy Jarmon Deceased It is from chese spwified circumstaaces

constituting gross negligence on the part of Defendant DC that the injuries and damages

20

complained of herein arose Accodingly Plaintiffs saek recovery of exemplary damages herein

against Defendant LX in an amount equal to the greater of two times the amount of economic

damages herein plus an amount q u a l to any noneconomic damages found by the jury not to

cxcecd $75000000 or $200~00

m PRIIJUDCMENTINTEREST

29 The above and foregoing acts andor omissions of Defendant Dc have caused

damages to Plaintiffs that entitle them to the recovery of prejudgment mterest on the damages

sustained

P R A W

WHEREFORE PMMSES CONSIDERED Plaintiffs pray that upon final trial hereof

Plaintiffs have judgment against Defendants jointly and severally in an amount in excess of the

jurisdictional limits of this Court together with their costs prejudgment and post-judgment

interest as allowed by law attorneys fees as allowed by law exemplary damages as deterrmned

by the trier of fact and that Plaintiffs be granted such other and b t h e r relief at law or in equity

general or special to whch they may show themselves justly entitled

Respectfully submitted

WALTMAN 8 G a r s w

LYM A Grisham State Bar No 08505500 Robert B Wdtman State Bar No 20822500 701 Texas Avenue Suite 106D College Station Texas 77840 Telephone 9796940900 Facsimile 979693-0840

21

THE COOKE WILSON LAW FIRM PC Chistopher C Cook State Bar No 00795303 16 N Mill Sheet Clebume TX 76033 Telephone 81755amp1811 Facsimile 8171558-1846

ATTORNEYS FOR PLAwrIFFS

PLMNTIFPS REQUEST A TRIAL BY JURY

F

CERTIFICATE OF SERVICE

I hereby certify that pursuant to TEX R CN P 2la a true and cohect copy of the foregoing has been forwarded via hand delivery telephonic document transfer andor ovemight mail andor US Mail Certified R e m Receipt Requested to all attorneys of record on this the - day of 2007

Lynn A Crrisham

22

O c t 1 5 2 0 0 9 4 02PM W a l t m a n amp G r i s h a m 9 7 9 - 6 9 3 - 0 8 4 0 N o 9 6 0 6 P 3

Page 1 of 2 FARS Encyclopedia

2006 Fatality Analysis Reporting System e ACCIDENT LEVEL US DapmnwtofTm ~d~~~

01-Prhcipl AtWIal 11PrIndplArtsrisl- InWslale

03-Mimr Atterid 14h4imr Artmi01 MMajor Cal+r 15-Colledor

16-Local Road or S b t eetlO-Unknown Urban

LOCAL STREET 5-Sand Din Oil

ODNOI collum with tmw vehicle Ol-Front4oRar (indudes Rear-Endl 02-Fmnt-tDFmnt (mduder Head-on) OS-Front-bSide S m D i d o n M-FmnthkSm OFQOamp~ DireeZiOn


D M n l m n c d E x i t ~ Relaled 14-Cros80ver-Reiated ARRIVAL TIME EMS 15-Olher Locsbon In lnlwchnwe W-Rad GIamp Cmsa+o

07-CmuOW-Waled 19 -UnWn Inlerchange ampea 0 8 - D m a y Accaaa Related w - u n w n WWNdNoWled 8998-Unknown if Arnved OO-Unknorm - Non-lnterchange 0097-Canceled 99QOUnLmwn

Mrtary Time Exwt

RELATION TO ROADWAY m EMS TIME AT HOSPITAL 01-On Roadway 02-Shwldef 03-Median w-Roadr(de

~

o g ~ f Roadway - Lwtmn unknaun M m V m e ficepv 07-In PaMw Lane 1o-sspram 0097-Can081ed 00SOUnknown

Lane

WW-NotTmsprted 9998Unknown if Transparled

1 1-Two-way Continuous LBR-Turn RELATED FACTORS 101010 IP ACCIDE NT RELATED FACTORS CODES

I I - 2-Dindsd Hghway Msdian Svlp (Wthoul Tramc Bemarl Ramp 3-Chvd~I Hlphwy Msddrn Svlp (wm Tram Earner) Wnknam

NUMBER OF TRAVEL LANES u ~

m a l Valw Exw 7 - S e m or MOR Lams 9-Unknown

1 httpwww-fars n dot ~ o ~ ~ ~ ~ T o o ~ ~ u ~ S ~ t i o ~ A c c i d e n ~ i s p l a y F o ~ a s p x S h o 10272010


2006 Fatality Analysis Reporting System Q VEHICLE LEVEL US DqpRwffrrf1- ~ d H g ~ T r ~ shty hhdramptampl

Actual Value if Total Knwn Except 88-06 or More

I-MOmr Vehide in Transport 4-Workinp Motor Vehide Huhway W-NonGoilision l S T w 1 Vat-in-Motionrsquo Condition 2-Momr Vehids Not in - Construction Maintenance Ut i l i i Only)

GSA CODES Except 00-Not Applicsbk 95Military Vehicle 92-NO RepIttrpSon 97-Foreipn Countay

de Compartment Intrusion Unkncwn)

Omar Private Ownw Listed) ffiovemnmnt Vehicle

ampNot used as a Bus 5-UsadasaTourEus

r of Trailers UnknOwn inp Anomer Motor Vehicle

EMERGENCY USE

200~6 (seats 9-15 pp including driver)

httpllwww-fars n dotgovQueryToo~Que~Sectio~ehicleDi~~yFo ~ ~ p xShow 10272010


OgAuto Transporter 07-Garbage I Refuse

08-Entamp n Parked Position OeContrd(ed Mm~m~arinp to

Maneuver Reported 5-Steering and BraWng (evldenca or mSfkeUant) Staled) Idd nuW dtihr 60mer Awidanca M a n m r

8-Ud Repaned I l n d u s i v e (by plica)

h t t p ~ n d o t g o v Q u e ~ T o o l Q u ~ S e c t i o ~ e h i c l e D ~ ~ y F o ~ ~ p x S h o w 1 02720 1 0

FARS 481432

FARS 481432

EWR Summary 2010 Quarter 1 Chrysler Submissions

Make JEEP

Deaths 1

Model GRAND CHEROKEE

Injuries 0

Model Year 2004

VIN 1J4GX48S94C

StateForeign Country TX

Incident Date 07102009

Sequence ID 28

Reported Components

A Fire Related

B Fuel System


2009 Fatality Analysis Reporting System CRASH LEVEL

OTTrnqmatim Q U9 No(knrlHBhVayTNncSW wnlsblkn

Ol-Principel M a l - il-Prinsipl Arterial - Interstate

lCMiMr mrial

1ELoCsl Road or Skeet beat 1PUnLmwn Urban

LOCAL STREET

ila (Auurneu Dedmal)

00-Not CoW~~~uirn Motor Vehicle 02-F-bFaor (inclueae Rear-End) M-FmrclpFmnt (indudsr Head-on) OFmnbtc-Slde Same Direction WFmnampbSida Opporlte Direction 10-Rear-bRear OS-Fmnt-to-Side Righl Angle (include8 ll-Omer(EndSwipeaand

Unknown rAmved

farsnhtsadotgovQueryTooVQuerySectio~AccidentDisplayFo~aspxSho 10272010

FARS Encyclopedia Page 2 of 2 j

ICCmuover-Related Mllilary Tima Except 15-OIher LOCBtiwn in Interchange 1 9 - U n k m n Inlorchange Area

wOn Roadway - Location 0 7 4 Pahing Lnnellone 1o-ssParatw 1 I -Twway Continuous Left-Turn

W e TmmcWaylOulsids RigMd- O B U n b w n

I-Nd P h y W i y D W (TvmWay TraRrwsy)

Adud Value Except

httpwww-fars n h t s a d o t g o v Q u e ~ T o o Y q 10272010


6 2009 Fatality Analysis Reporting System VEHICLE LEVEL

on Maintanance

OH0 Undenida w Ovenide

[ouler Pdvab Omer Liited) ylGovemment Vehicle

Unklwrrn But Uae

If Lighl or MedlHeavy

ampNo Trailing U n b Yes Ow Trailing Unit Z-Ysa Two Trailing Unb Linkage

CYes Number of Trailers Unknown SVehkIe Towing Anothw Motor VBhicie -Fixed

owiw AnolheI Mom Vehide - Non-

Sewicea Vehicle


22-Bus

euro-Unknown Cargo Body Type OBAutoTransponer 87-Other 07-Garbape I Refuse OBGrain Chips Gravel 99-Unknown WWk - Trailm

O l l - E ~ g a Parked Pornion o ~ ~ n b o l l e d Msruwenng to

m n DE HM4(Class HM5

ampNo Avddance Maneuwr Reported 5Sleeaeting and Brakinp (eviden Blank Blanks Blilnk Blank 0-Not 0000-Not OampNolApplicparahle ampNot npplicable APplicaMe Actual i d o i l Applicable 1-Yea Adual4digit Number(wilh 1-No 2-Yea Number leading zem) 2-Yea ampNot 888ENol 88-NoI Reported 8-Not Reported Reported Reported

Number)

h t t p ~ ~ - ~ n d o t g o v Q u e r y T o o l S h o w 1 02720 1 0

of 2 FAFS Encyclopedia

2003 Fatality Analysis Reporting System ACCIDENT LEVEL

US Dqmlmll d T m m t amp U f m d ~ T n l R c S d d y Acbldrwdkm

9999-Unknown

10-Local Road 01 Street trattlS-Unkncwn urban

3-Dark but Lighted

Ol-Fm-tPFampar OndUQs amp-End) 0 2 - F ~ t o F m t Ondudes Head-on) 03-FmtPSidS Same Direction lO-Rear4c-Rear

ll-Other(End Swipe3 and

99-Unknown toSidrUnpCLHrsdion Not

NOKINTERCWHOE INTERCHANGE ARE4 lO-lnteRamplia 11-lnlBrsBClim Related 12-Driveway -ea

15-Olher Locam In Interchange

M D r h W V rUr 8tC Z-Entrrnce~Exit Ramp Related 05-EnlramampxB Ramp Wted 14-Cr016~er-ReWed OSRd G d - M

httpwww-fars nhtsadotgovQue~Too~Que~Sectio~AccidentDisplayFormaspxSho 10272010

FARS Encyclopedia of 2

I ___







WTH OTHER VEHICLE




01-VaruEnclosed Box






SS-Unknorm




an Amculalad Vehi


FARS 480273

CAUSE NO 200600134












following





II lampKmS



















CODE

2





V uC2-s













death



herein

3
















principals

n CAUSES OF ACTION






4


aud






















5





subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)



I ___







WTH OTHER VEHICLE




01-VaruEnclosed Box






SS-Unknorm




an Amculalad Vehi


FARS 480273

CAUSE NO 200600134












following





II lampKmS



















CODE

2





V uC2-s













death



herein

3
















principals

n CAUSES OF ACTION






4


aud






















5





subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)





WTH OTHER VEHICLE




01-VaruEnclosed Box






SS-Unknorm




an Amculalad Vehi


FARS 480273

CAUSE NO 200600134












following





II lampKmS



















CODE

2





V uC2-s













death



herein

3
















principals

n CAUSES OF ACTION






4


aud






















5





subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)



SS-Unknorm




an Amculalad Vehi


FARS 480273

CAUSE NO 200600134












following





II lampKmS



















CODE

2





V uC2-s













death



herein

3
















principals

n CAUSES OF ACTION






4


aud






















5





subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)


FARS 480273

CAUSE NO 200600134












following





II lampKmS



















CODE

2





V uC2-s













death



herein

3
















principals

n CAUSES OF ACTION






4


aud






















5





subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)


CAUSE NO 200600134












following





II lampKmS



















CODE

2





V uC2-s













death



herein

3
















principals

n CAUSES OF ACTION






4


aud






















5





subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)


II lampKmS



















CODE

2





V uC2-s













death



herein

3
















principals

n CAUSES OF ACTION






4


aud






















5





subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)






V uC2-s













death



herein

3
















principals

n CAUSES OF ACTION






4


aud






















5





subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)

















principals

n CAUSES OF ACTION






4


aud






















5





subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)



aud






















5





subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)






subject vehick


the subject vehicle
















6








of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)









of a rear crash and















7



















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)




















subject vehcle


the subject vehicle


8






















of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)























of a rear crash and

9





Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)






Plaintiffs



















IO
















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)

















subject vehicle


the subject vehicle




11




















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)





















of a rear crash and



12

r
























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)

























13











subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)












subjecr vehicle


the Subject vehicle










14














of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)















of a fear crash and








15









decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)










decedent




imminent death

b

c

d








16








lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)









lived









b

c

d

Ix DAMAGES





a

b



17


imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)



imminent death





25









the future



in the future



the future

b

c

d

e

f

18








a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)









a

b

C

d

e

f

0 C1

h

i

j











future





19
























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)

























20




cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)





cxcecd $75000000 or $200~00




sustained

P R A W








WALTMAN 8 G a r s w


21




F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)





F



Lynn A Crrisham

22












Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)













Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)


of 2 FARS Encyclopedia










Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)





Mrtary Time Exwt


~


Lane
















EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)











EMERGENCY USE









FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)








FARS 481432

FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)


FARS 481432


Make JEEP

Deaths 1


Injuries 0

Model Year 2004

VIN 1J4GX48S94C



Sequence ID 28

Reported Components

A Fire Related

B Fuel System





lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)






lCMiMr mrial


LOCAL STREET



Unknown rAmved







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)







Adud Value Except




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)




on Maintanance



Unklwrrn But Uae





Sewicea Vehicle


22-Bus





Number)



22-Bus





Number)


fars# 450884

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