MARGARET ELIZABETH ROBINSON       
Plaintiff,                                     

vs.                                                                  JURY TRIAL DEMANDED

MARK KOEHLER
Defendant.

PETITION - MOTOR VEHICLE AND BICYCLE  ACCIDENT

             COMES NOW Plaintiff, Margaret Elizabeth Robinson, and for her Petition against Defendant, Mark Koehler, states as follows:

2.         The amount in controversy exceeds $25,000, exclusive of interest and costs.    

3.             Venue is appropriate in St Louis County, State of Missouri.

4.         On or about 9/6/2006, Plaintiff was a bicyclist traveling on Midland Rd. approaching its intersection with Wismar Rd

5.         At the same time, a vehicle owned and operated by Defendant was traveling the same direction as Plaintiff and the Defendant overtook Plaintiff and made an abrupt and unsignaled right turn onto Wismar without yielding to Plaintiff.

6.          The Defendant was negligent and caused a collision between his vehicle and
the Plaintiff, a bicyclist.  

7.         The Defendant owed Plaintiff the highest degree of care in operating his vehicle prior to and during the previously-referenced turn and collision.

8.             Defendant breached the duty he owed Plaintiff in the following respects:

                        A)        Defendant operated his vehicle in an unsafe manner by driving at an   excessive rate of speed for the traffic conditions;

                        B)        Defendant failed to obey traffic signs;

                        C)        Defendant failed to operate his vehicle in a safe manner;

                        D)        Defendant failed to avoid the collision; and

                        E)         Defendant failed to yield.

9.         As a direct and proximate result of Defendant’s negligence, Plaintiff was caused to suffer severe physical injuries, including but not limited to a severely fractured elbow causing permanent disabling injuries, permanent disfigurement, past and future pain and suffering, loss of enjoyment of life, and past and future lost wages and medical expenses.  

            WHEREFORE, Plaintiff requests the Court to enter judgment in his favor and against the Defendant, and award her compensatory damages in an amount to be proven at trial to be fair and reasonable in excess of $25,000; to award her prejudgment interest, attorney fees, and the costs of this action; and to grant such other relief as the Court may deem necessary and proper.