On December 10, 2021 a
Complaint,Petition
was filed
involving a dispute between
Samuel A Maher,
and
Terrence E Valencic,
for TORT-M.V. ACCIDENT
in the District Court of Cuyahoga County.
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NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
New Case Electronically Filed: COMPLAINT
December 10,2021 10:12
By: DAVID P. THOMAS 0061988
Confirmation Nbr. 2423921
SAMUEL A. MAHER CV 21 956953
vs.
Judge: DICK AMBROSE
TERRENCE E. VALENCIC
Pages Filed: 3
Electronically Filed 12/10/202110:12/ /CV21 956953 / Confirmation Nbr. 2423921 /CLLMD
IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
SAMUEL A. MAHER ) CASE NO.
6805 Mayfield Road, Apt. 1516 )
Mayfield Hts., OH 44124 )
)
) JUDGE:
Plaintiff, )
)
vs. ) COMPLAINT
) (Jury Demand Endorsed Hereon)
TERRENCE E. VALENCIC )
9605 Musket Drive )
Mentor, OH 44060 )
)
)
)
Defendant. )
Now come Plaintiff, Samuel A. Maher, and for his Complaint against Defendant, Terrence
E. Valencic, states as follows:
COUNTI
1. On or about December 12, 2019, at approximately 7:45 AM at the intersection of
Cedar Road and Lander Road, in the City of Mayfield Heights, County of Cuyahoga, and State of
Ohio, Defendant operated a motor vehicle so as to collide with a motor vehicle operated by
Plaintiff.
2. The aforementioned collision was a direct and proximate result of the negligent acts
and omissions of Defendant while operating said motor vehicle.
3. As a direct and proximate result of the negligent acts and omissions of Defendant,
Plaintiff sustained injuries to his person causing him physical pain and mental suffering, which are
to some extent permanent in nature, and forced him to incur medical expenses as well as other out
Electronically Filed 12/10/202110:12 / / CV 21 956953 / Confirmation Nbr. 2423921 / CLLMD
of pocket expenses which will continue into the future.
4. As a direct and proximate result of the negligent acts and omissions of Defendant,
Plaintiff has been caused to suffer a loss of and interference with his ability to participate in and
perform his usual duties and activities and states that said loss and interference will continue into the
future. He further states that the effects of said injuries upon his general health and well being are to
some extent permanent.
5. As a direct and proximate result of the negligent acts and omissions of Defendant,
Plaintiff may have been caused to suffer a loss of income and earning capacity.
WHEREFORE, Plaintiff, Samuel A. Maher, demands judgment against Defendant,
Terrence E. Valencic, in an amount in excess of Twenty Five Thousand Dollars ($25,000.00) and to
be determined at trial. Plaintiff further demands judgment for the cost of this proceeding, interest
from the date of judgment and all other remedies in law or equity to which he is entitled.
/s/ David P. Thomas_
David P. Thomas (0061988)
24645 Shaker Blvd.
Beachwood, OH 44122
Telephone: (216) 621-9110
Facsimile: (888) 679-4770
Email: DavidPThomas1@me.com
Attorney for Plaintiff, Samuel A. Maher
Electronically Filed 12/10/202110:12 / / CV 21 956953 / Confirmation Nbr. 2423921 / CLLMD
JURY DEMAND
Plaintiffs hereby demand a trial by jury comprised of the maximum number of jurors
allowed by law.
/s/ David P. Thomas
David P. Thomas (0061988)
Attornes for Plaintiff
Electronically Filed 12/10/202110:12 / / CV 21 956953 / Confirmation Nbr. 2423921 / CLLMD
Document Filed Date
December 10, 2021
Case Filing Date
December 10, 2021
Category
TORT-M.V. ACCIDENT
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NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas New Case Electronically Filed: COMPLAINT December 10,2021 10:12 By: DAVID P. THOMAS 0061988 Confirmation Nbr. 2423921 SAMUEL A. MAHER CV 21 956953 vs. Judge: DICK AMBROSE TERRENCE E. VALENCIC Pages Filed: 3 Electronically Filed 12/10/202110:12/ /CV21 956953 / Confirmation Nbr. 2423921 /CLLMD IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO SAMUEL A. MAHER ) CASE NO. 6805 Mayfield Road, Apt. 1516 ) Mayfield Hts., OH 44124 ) ) ) JUDGE: Plaintiff, ) ) vs. ) COMPLAINT ) (Jury Demand Endorsed Hereon) TERRENCE E. VALENCIC ) 9605 Musket Drive ) Mentor, OH 44060 ) ) ) ) Defendant. ) Now come Plaintiff, Samuel A. Maher, and for his Complaint against Defendant, Terrence E. Valencic, states as follows: COUNTI 1. On or about December 12, 2019, at approximately 7:45 AM at the intersection of Cedar Road and Lander Road, in the City of Mayfield Heights, County of Cuyahoga, and State of Ohio, Defendant operated a motor vehicle so as to collide with a motor vehicle operated by Plaintiff. 2. The aforementioned collision was a direct and proximate result of the negligent acts and omissions of Defendant while operating said motor vehicle. 3. As a direct and proximate result of the negligent acts and omissions of Defendant, Plaintiff sustained injuries to his person causing him physical pain and mental suffering, which are to some extent permanent in nature, and forced him to incur medical expenses as well as other out Electronically Filed 12/10/202110:12 / / CV 21 956953 / Confirmation Nbr. 2423921 / CLLMD of pocket expenses which will continue into the future. 4. As a direct and proximate result of the negligent acts and omissions of Defendant, Plaintiff has been caused to suffer a loss of and interference with his ability to participate in and perform his usual duties and activities and states that said loss and interference will continue into the future. He further states that the effects of said injuries upon his general health and well being are to some extent permanent. 5. As a direct and proximate result of the negligent acts and omissions of Defendant, Plaintiff may have been caused to suffer a loss of income and earning capacity. WHEREFORE, Plaintiff, Samuel A. Maher, demands judgment against Defendant, Terrence E. Valencic, in an amount in excess of Twenty Five Thousand Dollars ($25,000.00) and to be determined at trial. Plaintiff further demands judgment for the cost of this proceeding, interest from the date of judgment and all other remedies in law or equity to which he is entitled. /s/ David P. Thomas_ David P. Thomas (0061988) 24645 Shaker Blvd. Beachwood, OH 44122 Telephone: (216) 621-9110 Facsimile: (888) 679-4770 Email: DavidPThomas1@me.com Attorney for Plaintiff, Samuel A. Maher Electronically Filed 12/10/202110:12 / / CV 21 956953 / Confirmation Nbr. 2423921 / CLLMD JURY DEMAND Plaintiffs hereby demand a trial by jury comprised of the maximum number of jurors allowed by law. /s/ David P. Thomas David P. Thomas (0061988) Attornes for Plaintiff Electronically Filed 12/10/202110:12 / / CV 21 956953 / Confirmation Nbr. 2423921 / CLLMD