DALE M, ROEHNIG, a Minor,
By JAMES J. ROEHNIG, Father and Next Friend;
LINDA F. ROEHNIG, Mother and Next Friend,
HERMAN A. SHULMAN
MOTION FOR A JUDGMENT BY DEFAULT
WHEREFORE, the Plaintiffs sue the Defendant and demand a jury to try this case. The Plaintiff should be awarded Twenty-two Thousand Dollars ($22,000). Both, the Plaintiffs and Defendant were residents of Davidson County, Tennessee on June 29th, 1993.
COMES the Plaintiff and sues the Defendant in the amount of Twenty-five Thousand Dollars ($25,000). The Plaintiff was only one and half years old on the date of the injury.
DALE M. ROEHNIG, a minor Plaintiff, sues HERMAN A. SHULMAN, the Defendant. Plaintiffs would show:
1. That both parties were residents of Davidson County and lived next door to each other at 2413 Valley Crest Drive. Nashville, Tennessee 37201. 2. That on June 29th, 1993 the Plaintiff was attracted to a riding mower being driven by the Defendant, the child approached the mower from the rear of the Defendant and the blade stroke his toes; and
3. That as a direct and proximate result of the negligence of the Defendant, the Plaintiff was injured.
COME the Plaintiffs, DALE M. ROEHNIG, at all and move for a Judgment by Default.
COMES the Plaintiff through his attorney and moves for a Judgment by Default.
My address is:
ROBERT W. MITCHELL (No. 32112)
Attorney for the Plaintiff
804 Stahlman Building
Nashville, TN 37201