1 Siddu Navaneetha

39005 Lochmoor Dr
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Cleveland, OH 44139
3 7657147243
siddun11@gmail.com
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF OHIO

7 Case No.: 06071999

8 LOGAN LOVELL,
9 Plaintiff,
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vs.
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PAT SAINSBURY,
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Defendant
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COMPLAINT

16 Plaintiff, LOGAN LOVELL, complains against Defendants, PAT SAINSBURY, as

17 follows:
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I. PARTIES
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1. Plaintiff, LOGAN LOVELL, (hereinafter “Plaintiff”) is an individual who
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is currently, and was at all times relevant herein, a resident of the State of Ohio,
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22 County of Cuyahoga, City of Cleveland.

23 2. Defendant, PAT SAINSBURY, (hereinafter “Defendant”) is an an

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individual who is currently, and was at all times relevant herein, a resident of the
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State of Ohio, County of Cuyahoga, City of Cleveland.
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3. All of the acts and/or failures to act alleged herein were duly performed
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 1 II. FACTS
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4. Plaintiff is an 18-year-old high school student attending his senior year at
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Mary Lincoln High School. He is a member of the swim team, and on track to
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receive a college swim scholarship.
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6 5. Defendant is an 18-year-old high school student attending his senior year

7 at Mary Lincoln High School. He is also a member of the swim team.

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6. On Friday, April 10, 2018, both Plaintiff and Defendant attended a school
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assembly for a Illinois Judges Association program entitled Seven Reasons To
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Leave The Party. The school has a zero tolerance policy regarding drugs,
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12 drinking, smoking, and curfew violations, especially for those on school athletic

13 or scholastic teams.
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7. On Saturday, April 11, 2018, both Plaintiff and Defendant are invited to a
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party at a peer, Kim Jordan’s home. They are told that Kim’s parents will be
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home, and the party is for a “movie night.”
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18 8. Upon arriving, the guests realize that Kim’s parents are not at home and

19 there is evidence of alcohol present, brought by guests in coolers. Both Plaintiff

20 and Defendant attend the party.
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9. Once Plaintiff made visual confirmation of the presence of alcohol, he left,
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taking two students (Pam Becker and Ryan Williams) with him.
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10. After leaving, Plaintiff and Defendant are involved in a traffic accident

25 between their two vehicles. Ambulances and police arrived at the scene, and
26 shortly afterwards, breathalyzers were administered. Plaintiff spoke with Officer
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Kerry Cambridge, who issued the Defendant a citation.
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PLEADING TITLE - 2
 1 11. Plaintiff sustained a broken leg, fractured wrist, concussion, and various
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soft tissue injuries. He underwent surgery for his leg and received treatment for
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the wrist fracture. In addition to spending 5 days in the hospital, he has had to
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endure over 45 physical therapy sessions and 5 follow-up visits to his orthopedic
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6 surgeon. His bills are estimated to be over $36,000.00 and counting.

7 12. Because of his injuries, Plaintiff’s swim scholarship has been put in
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jeopardy.
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III. CLAIMS FOR RELIEF
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12 A. Negligence

13 13. Defendant drove while under the influence of alcohol.

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14. Defendant was using a cell phone while driving.
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15. As a result of Defendant’s actions, Plaintiff has incurred costs in an
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amount in excess of $36,000.00, which will be proven at trial.
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18 B. Reckless Endangerment

19 16. Defendant had two passengers in his vehicle while driving under the
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17. Defendant caused physical harm, pain and suffering, and possible loss of
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swim scholarship to Plaintiff.
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18. Plaintiff’s injuries have resulted in damages in excess of $100,000.00,

25 which will be proven at trial.

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 1 IV. PRAYER FOR RELIEF
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WHEREFORE, Plaintiff prays for the following relief:
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1. For compensatory damages for medical costs and expenses, for past, present, and future
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in excess of $50,000;
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6 2. For loss of athletic scholarship and other damages in excess of $100,000;

7 3. For interest at the statutory rate; and

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4. For such other and further relief as this court deems just and equitable.
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I declare under penalty of perjury under the law of the State of Ohio that the foregoing is
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true and correct.
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13 Dated this 13th day of February 2020.

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Logan Lovell
16 39005 Lochmoor Dr
Cleveland, OH 44139
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Telephone: (765) 714-7243
18 siddun11@gmail.com
Plaintiff, in Proper Person
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 1 CERTIFICATE OF SERVICE
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I hereby certify that a true and accurate copy of the foregoing document

4 has been served upon:

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7 Pat Sainsbury
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9500 Arthur Dr
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Cleveland OH 44139
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by placing the same, postage prepaid in the United States Mail on this the 13 th
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day of February, 2020.
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________________________
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39005 Lochmoor Dr
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Cleveland OH 44139
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