COMPLAINT AND REQUEST FOR JURY TRIAL IN THE DISTRICT COURT OF LANCASTER COUNTY, NEBRASKA KWE PO, Plaintiff, v. ELIA VINCENTE, Defendant. Case Number: D02CI220003271 COMES NOW the Plaintiff, Kwe Po, through his attorney, Blake H.D. Maaske, and for his cause of action against the Defendant, Elia Vincente, states and alleges as follows: CAUSE OF ACTION 1. Plaintiff, Kwe Po, is a resident of Lincoln, Lancaster County, Nebraska. 2. Defendant, Elia Vincente, is a resident of Crete, Saline County, Nebraska. 3. On or about January 15th, 2021, a collision resulting in damages, for which relief is sought, occurred on Highway 33 in Lancaster County, Nebraska. On that day, Kwe Po was traveling eastbound on Highway 33. At the same time, Defendant, Elia Vincente, was traveling westbound on Highway 33 and crossed the center line, causing a collision with Plaintiff's vehicle. 4. The aforementioned collision was the direct and proximate result of the negligence of the Defendant, Elia Vincente, in one or more of the following particulars: a. Failing to yield the right of way; b. Failing to see what is in plain sight; c. Failing to keep a proper lookout; d. Failing to yield to a vehicle that is in a favored position; and e. Failing to look at a time when looking would have been effective to avoid the collision; f. Driving in the wrong lane of traffic. 5. As a proximate result of the aforementioned collision, the Plaintiff, Kwe Po, suffered the following compensable damages for which the Defendant, Kwe Po, is liable: a. Nature and extent of the injury to his person, including head, chest, and right knee and right shoulder, resulting in permanent impairment; b. Medical expenses to date, in the amount of, $28,358.90 or in an amount to be determined at trial; c. The reasonable value of medical expenses reasonably certain to be needed and provided in the future; d. Lost wages to date in the amount of $2,500.00 or in an amount to be determined at trial; e. The reasonable value of future lost wages reasonably certain to be incurred in the future; f. Physical pain and mental suffering to date; g. Physical pain and mental suffering reasonably certain to be experienced in the future; h. Inconvenience experienced to date; and i. Inconvenience reasonably certain to be experienced in the future. WHEREFORE, Plaintiff, Kwe Po, prays for judgment against the Defendant, Elia Vincente, for all of his general and special damages, for costs, and for such other relief as is just and equitable. DATED this 23rd day of September, 2022. BY: KWE PO, Plaintiff BY: DOWDING, DOWDING, DOWDING & URBOM 201 N. 8th Street, Suite 242 P.O. Box 83103 Lincoln, NE 68501-3103 Phone: (402) 477-1010 Fax: (402) 477-9913 E-mail: blake@dowdinglaw.com BY: /s/ Blake I.D. Maaske BLAKE H.D. MAASKE, #26066 Attorney for Plaintiff REQUEST FOR JURY TRIAL Plaintiff hereby requests a jury trial for the cause of action against Defendant. BY: /s/ Blake H.D. Maaske #26066 CR — February 22, March 01, 08, 2023 ZNEZ
