(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this brain injury/automobile accident case and its proceedings.)
PLAINTIFFS’ TRIAL BRIEF
INTRODUCTION
On August 20, 2005, Tammy Martinez was driving her mother, Maggie Smith, and her two nieces, 19-month-old Alexa Martinez, and 5-year-old Amanda April, northbound on Mission Boulevard (Mission) in Sacramento. The weather was clear and sunny at the time of the accident. As Martinez approached the intersection of Mission and Hollis, she intended to turn left to go westbound. Mission is a two-lane, north/south street in a business district. Hollis is a residential street with one lane in either direction. The intersection is controlled by standard 3-phase lights. There are no left-turn pockets, or left-turn arrows. On this day, numerous pedestrians were walking in this business district, and vehicle traffic was moderate. The posted speed limit at the intersection is 35 mph.
Defendant Ralph Black was 18 years of age and was employed by Automotive Group as a used car salesman. He was in the process of selling a used Ford F-150 pickup truck to a customer. Black’s manager instructed him to take the pick-up and get it filled with gasoline while the sales contract was being drafted.
Black left the lot at Automotive and traveled westbound on Mission and turned left to go south on Mission. His destination was a Chevron gas station, located at Laurel and Mission, on the east side of Mission. Black initially turned into the Number 1 southbound lane on Mission and somewhere in the course of the three blocks getting to Hollis, he changed to the number 2 lane (even though the gas station was on his left). (See Part 2 of 4.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.