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COMPLAINT FOR DAMAGES FOR NEGLIGENCE

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The Law Offices Of

Young Wooldridge, LLP

A LIMITED LIABILITY PARTNERSHIP COMPOSED OF PROFESSIONAL CORPORATIONS

Westchester Corporate Plaza ● 1800 30th Street, Fourth Floor ● Bakersfield, CA 93301-5298 ● Telephone 661-327-9661 ● Facsimile 661-327-1087 ● http://www.youngwooldridge.com

The Law Offices Of

Young Wooldridge, LLP

1800 30th Street, Fourth Floor

Bakersfield, CA 93301

Telephone: (661) 327-9661

Fax: (661) 327-1087

E-mail: tbrill@youngwooldridge.com

Thomas A. Brill, Esq., SBN 125356

Attorneys for Plaintiffs

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

JASVIR SINGH; RANVIR SINGH, 

Plaintiffs,

vs.

ROBERTS TIRE SALES, INC., an Arizona 

Corporation, individually and dba ROBERTS 

TIRE COMPANY; WILLIAM R. STATON; 

FLEET EQUIPMENT CORPORATION, a 

New Jersey Corporation, 

 Defendants.

Case No.

COMPLAINT FOR DAMAGES FOR 

NEGLIGENCE

DEMAND FOR JURY TRIAL

COMES NOW plaintiffs JASVIR SINGH and RANVIR SINGH, and for their 

Complaint against defendants allege and states as follows:

I. PARTIES, JURISDICTION, AND VENUE

1. At all times relevant hereto, plaintiff JASVIR SINGH (hereinafter “J.SINGH”) is 

and was a resident of Kern County, California. He was injured while driving in Mohave County, 

Arizona.

2. At all times relevant hereto, plaintiff RANVIR SINGH (hereinafter “R.SINGH”) 

is and was a resident of Kern County, California. He was injured while riding as a passenger in a 

vehicle driven by plaintiff J. SINGH in Mohave County, Arizona.

Case 3:18-cv-08009-DLR Document 1 Filed 01/29/18 Page 1 of 4
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COMPLAINT FOR DAMAGES FOR NEGLIGENCE

2

The Law Offices Of

Young Wooldridge, LLP

A LIMITED LIABILITY PARTNERSHIP COMPOSED OF PROFESSIONAL CORPORATIONS

Westchester Corporate Plaza ● 1800 30th Street, Fourth Floor ● Bakersfield, CA 93301-5298 ● Telephone 661-327-9661 ● Facsimile 661-327-1087 ● http://www.youngwooldridge.com

3. Defendant ROBERTS TIRE SALES, INC., is, and at all times relevant to this 

Complaint was, a corporation organized and existing under the laws of the State of Arizona, with 

its principal place of business in Arizona.

4. At all times relevant hereto, defendant WILLIAM R. STATON (hereinafter 

“STATON”), an individual, is and was, upon information and belief, a resident of the State of 

Pennsylvania. 

5. Defendant FLEET EQUIPMENT CORPORATION, is a corporation organized 

and existing under the laws of the State of New Jersey, and whose principal place of business is 

in New Jersey. 

6. This court has jurisdiction over the subject matter of this action pursuant to 28 

U.S.C. §1332, as the respective parties are citizens of different states. Venue is properly set in 

the United States District Court, Arizona District pursuant to 28 U.S.C.§§1391(b)(2), as the 

causes of action alleged herein arise from an accident and injuries which occurred in this judicial 

district. 

7. The amount in controversy is in excess of $75,000, in that plaintiffs J. SINGH 

and R. SINGH have suffered severe injuries as a result of the accident. 

II. FACTS COMMON TO ALL CLAIMS

8. On or about February 1, 2016, at approximately 1:21 a.m., plaintiff J. SINGH was 

driving a 2016 Volvo truck tractor and pulling a white box trailer, traveling in the #1 lane of 

westbound Interstate 40 , in the City of Yucca, in Mohave County, Arizona. At the same time, 

defendant STATON, who was driving a 2006 Peterbuilt commercial motor vehicle straight truck, 

registered to defendant ROBERTS TIRE COMPANY, was traveling eastbound in the #1 lane of 

westbound Interstate 40, directly the path of plaintiff J. SINGH’s oncoming tractor trailer 

vehicle. Plaintiff J. SINGH was unable to avoid colliding with STATON and sustained personal 

Case 3:18-cv-08009-DLR Document 1 Filed 01/29/18 Page 2 of 4
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COMPLAINT FOR DAMAGES FOR NEGLIGENCE

3

The Law Offices Of

Young Wooldridge, LLP

A LIMITED LIABILITY PARTNERSHIP COMPOSED OF PROFESSIONAL CORPORATIONS

Westchester Corporate Plaza ● 1800 30th Street, Fourth Floor ● Bakersfield, CA 93301-5298 ● Telephone 661-327-9661 ● Facsimile 661-327-1087 ● http://www.youngwooldridge.com

injuries in the accident. Plaintiff R. SINGH was a passenger in J. SINGH’s truck trailer and was 

in the sleeper berth at the time of the accident. R. SINGH sustained personal injuries as a result 

of the collision.

9. Plaintiffs are informed and believe that defendant FLEET EQUIPMENT 

CORPORATION is an Interstate Carrier for the 2006 Peterbuilt commercial motor vehicle 

straight truck driven by Defendant STATON.

III. CAUSES OF ACTION

NEGLIGENCE

10. Plaintiffs reallege and incorporate herein by reference the allegations set forth in 

paragraphs 1 through 9 of this Complaint.

11. At said time and place, defendants, and each of them, negligently maintained, 

operated, controlled and entrusted said vehicle. A direct result of defendants’ use, operation 

control and driving of its vehicle was to cause a collision between defendants’ vehicle and 

Plaintiff S. SINGH’s vehicle, directly causing the damages and injuries hereinafter set forth.

12. As a direct and legal result of the defendants’ negligence, and each of them, 

plaintiffs were hurt and injured in their health, strength and activity, sustaining injury to their 

persons, all of which injuries have caused, and continue to cause, plaintiffs great mental, 

physical, emotional and nervous pain and suffering. 

13. As a further direct and legal result of the negligence of defendants, and each of 

the, plaintiffs were required to incur medical and incidental expenses. 

IV. DAMAGES

14. Plaintiffs have suffered general and special damages, incidental and consequential 

damages as the direct result of the acts and omissions of the defendants, and each of them, which 

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COMPLAINT FOR DAMAGES FOR NEGLIGENCE

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The Law Offices Of

Young Wooldridge, LLP

A LIMITED LIABILITY PARTNERSHIP COMPOSED OF PROFESSIONAL CORPORATIONS

Westchester Corporate Plaza ● 1800 30th Street, Fourth Floor ● Bakersfield, CA 93301-5298 ● Telephone 661-327-9661 ● Facsimile 661-327-1087 ● http://www.youngwooldridge.com

damages shall be fully proven at the time of trial. These damages include, but are not limited to: 

General pain and suffering; physical injury; loss of enjoyment of life; both past and future; 

medical and medical-related expenses, both past and future; emotional distress; and all other 

ordinary, incidental and consequential damages as would be anticipate to arise under the 

circumstances.

V. DEMAND FOR JURY

15. Plaintiffs hereby demand a trial by jury.

PRAYER FOR RELIEF

WHEREFORE, plaintiffs pray for the following relief:

A. That the Court award plaintiffs judgment against defendants in such sums as shall 

be determined to fully and fairly compensate the plaintiffs for all general, special, incidental and 

consequential damages incurred, or to be incurred, as the direct and proximate result of the acts 

and omissions of the defendants, in an amount to be proven at trial;

B. That the Court aware the plaintiffs their costs;

C. That the Court award the plaintiffs the opportunity to amend or modify the 

provisions of this Complaint as necessary or appropriate after additional or further discovery of 

is completed in this matter, and after all appropriate parties have been served; and

D. That the Court award such other and further relief as it deems necessary and 

proper in the circumstances.

RESPECTFULLY SUBMITTED this 29th day of January, 2018.

THE LAW OFFICES OF 

YOUNG WOOLDRIDGE, LLP

By /S/ Thomas A. Brill.

Thomas A. Brill, Esq. 

Attorneys for Plaintiffs

Case 3:18-cv-08009-DLR Document 1 Filed 01/29/18 Page 4 of 4