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Robert Howard, the plaintiff and the defendant(s), in response to the allegations of the complaint on the file enclosed herewith, rejects, affirms, and makes the following allegations:
confirms that the Plaintiffs are real people and Arkansas citizens.
Affirms that the defendants are individuals, are residents of Arkansas at
the time of this complain and employees of the stated organization.
Affirms that on May 31, 2001, about 1528hours, the defendant exited Interstate 540 at State Highway 282 Arkansas and failed to stop at the stop sign thereby causing the accident. The Plaintiffs also affirm that the 1990 Blue Bird Corporation bus was operated by the Mountainburg, Arkansas, Public Schools at the time of the accident. The bus was hit and rotated about 300 degrees clockwise. The occupants of the mentioned vehicle were injured severely.
Affirms that the probable cause of the accident as addressed by the national Transport and Safety Board report was poor maintenance of the bus owned by the 1990 Blue Bird Corporation.
Affirms that majority of the occupants of the vehicle sustained fatal injuries and of all the school buses that were parked, one was partially ejected which just explains the extent of the impact the 1990 Blue Bird Corporation bus had on the other buses.
Affirm that the 1990 Blue Bird Corporation 65-passenger school bus was driven at 48 mph when it collided with the right side of the westbound vehicle after having entered the intersection without observing the traffic lights.
Affirm that the vehicle was partially separated from the chassis owing to the impulse of the collision.
Affirm that the tractor semitrailer rotated about 60 degrees and overturned after continuing across the roadway and it later came to rest on its left side.
Affirm that the vehicle rotated clockwise at almost 300 degrees and managed to rest on its right side on the eastbound shoulder of State Highway 282.
Affirms that another probable cause of the accident was the driver’s inability to halt the tractor semitrailer at the stop sign at the bottom of the ramp. This was due to the brakes inefficiency to perform and it was as a result of poor maintenance and inadequate inspection.
The defendant failed to maintain the vehicle and operated it in its poor condition
WHEREFORE, the plaintiffs seek compensation in hospital bills, attorney fees, compensation on the damaged bus, and personal compensation to the amount of $70000, together with court fees.
Dated this 19th Day of November 2017.
United States of America.
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