MARSHALL - After being involved in a severe rear-end collision involving a tractor-trailer, Deborah Bailey filed a personal injury lawsuit against the truck driver Juan Cavallini Ramirez and his employers Miller Equipment Co. Inc. and Carson & Barnes Circus Co. Inc.

The federal lawsuit was filed on Oct. 21 in the Eastern District of Texas, Marshall Division.

The motor vehicle crash occurred on Oct. 24, 2009, as Bailey was driving a 2006 Dodge Stratus eastbound on Texas Highway 154 in Upshur County.

Defendant Ramirez was driving a 1998 Freightliner truck and towing a semi-trailer, following behind Bailey. According to court documents, Ramirez failed to control the speed of the tractor-trailer and struck the rear of the Bailey's vehicle.

Defendant Ramirez is accused of negligence for failing to maintain an assured clear distance between two vehicles, failing to keep a proper lookout, failing to timely apply his brakes, failing to control the vehicle, failing to act or respond in a reasonable manner and failing to control the speed of the vehicle.

Defendants Miller Equipment and defendant Carson & Barnes Circus are accused of negligent entrustment to an unlicensed, incompetent or reckless driver, hiring and retaining an unlicensed, incompetent or reckless driver and failing to properly train its drivers.

The plaintiff is seeking damages for medical expenses, physical pain and suffering, mental anguish, physical impairment, physical disfigurement, loss of earning capacity, interest, court costs and fees.

Bailey is represented by Brent Goudarzi of Goudarzi & Young in Gilmer. A jury trial is requested.

U.S. District Judge David Folsom is assigned to the case.

Case No. 2:11-cv-00459

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