IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF OKLAHOMA
PAULA PEKINST, Plaintiff,
v.
DAVID DANSERUN, Defendant
COMPLAINT
The Plaintiff states for this cause of action as follows:
I.
PARTIES
1. Plaintiff, Paula Perkinst, resides in and is a citizen of the state of Oklahoma.
2. Defendant, David Danseurn, resides in and is a citizen of the state of Texas.
II.
JURISDICTION AND VENUE
3. This Court has jurisdiction over the lawsuit under the provisions of 28 U.S.C. Section
1332.
4. The parties to this lawsuit are citizens of different states, and the matter in
controversy exceeds the sum or value of $75,000.00, exclusive of interest and costs.
5.
6.
7.
8.
III.
FACTUAL ALLEGATIONS
Just before midnight on August 28, 2021, Plaintiff was crossing Boyd Street in
Norman, Oklahoma. Plaintiff was crossing with the light and inside the
crosswalk.
Defendant hit Plaintiff with his motor vehicle, a white Mazda, while Plaintiff was
crossing the street.
Plaintiff suffered a broken leg, a broken wrist, and a concussion.
Plaintiff currently has $200,000 in unpaid medical expenses.
IV.
CLAIMS FOR RELIEF
9. Plaintiff seeks recovery for all available damages under any applicable statute
and/or common law of the state of Oklahoma.
10. Plaintiff has suffered damages which include, but are not limited to, the
following:
a. Physical pain and mental anguish sustained in the past;
b. Physical pain and mental anguish that, in reasonable probability, Plaintiff
will sustain in the future;
c. Loss of earning capacity sustained in the past;
d. Loss of earning capacity that, in reasonable probability, Plaintiff will
sustain in the future;
e. Medical care expenses in the past;
f. Medical care expenses that, in reasonable probability, Plaintiff will incur
in the future.
V.
REQUESTS FOR RELIEF
11. Plaintiff demands judgement against defendant for at least $200,000, plus costs
and such other relief as the Court deems proper.