In a recent court filing, Michele Charise Haines has lodged a negligence complaint against Andrew Manuntag Navarro in the Superior Court of California, County of San Francisco. The complaint, filed on May 13, 2024, alleges that Navarro's negligent driving resulted in a severe motor vehicle collision that caused significant injuries to Haines.
According to the details provided in the complaint, the incident occurred on May 24, 2022. Haines was a restrained passenger in a 2017 Ford E-450 traveling eastbound on John Muir Drive near Lake Merced Boulevard in San Francisco. Navarro was driving a 2005 Toyota Camry directly behind Haines' vehicle. The complaint states that Navarro operated his vehicle "without due care," resulting in a collision with Haines' vehicle. As a result of this incident, Haines claims to have suffered "severe, traumatic, debilitating, and permanent injuries" necessitating extensive medical care.
The complaint further alleges that Navarro was not acting alone but as part of a larger group of defendants referred to as DOES 1-100. These unnamed defendants are believed to be agents, servants, employees, or joint venturers of each other and were allegedly negligent in their roles related to the incident. The plaintiff intends to amend the complaint once the true identities and capacities of these individuals are ascertained.
Haines' legal team argues that all defendants owed her a duty of care to operate their vehicles reasonably and safely. They claim that this duty was breached through careless and negligent actions by Navarro and others involved. Specifically, it is alleged that Navarro's operation of his vehicle directly led to the collision and subsequent injuries sustained by Haines.
As part of her legal action, Haines is seeking various forms of relief from the court. She is asking for general damages for past and future physical, mental, and emotional pain and suffering. Additionally, she seeks special damages for past and future medical expenses, loss of earnings, loss of earning capacity, and other economic losses incurred due to her injuries. Furthermore, she requests prejudgment interest and coverage for the costs associated with bringing the suit forward.
Representing Michele Charise Haines are attorneys Alan A. Ahdoot and Christopher B. Adamson from Adamson Ahdoot LLP based in Los Angeles. The case has been assigned Case No.: CGC-24-614593 under unlimited jurisdiction within the Superior Court of California for San Francisco County.