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Civil indictment

Plaintiff: Jia Baohe, male, the Han nationality, born in April 20, 1979, Castle black township in Wangdu County in Hebei Province, Gu Xian Cun, Baoding City No. 550. Now living in Baoding City area Xue Liu Ying Cun Village No. 132. Tel: 15233752279

Defendant: peak, male, Han nationality, identity card number: 130629198503220058, Baoding City, Rongcheng County Town Dong Niu Xi Zhuang village. Tel: 13931290962

Defendant: Guan Zhiliang, male, the Han nationality, identity card number: 130629195812050415, Shahe Township in Rongcheng County of Hebei Province wild bridge.

Defendant: if you property insurance Limited by Share Ltd Baoding branch. Telephone: * *

Legal representative:Hu Jintao Position: General Manager

Address: Baoding city *********.

The dispute over the responsibility of traffic accident of motor vehicles

The claim: a request in accordance with the law, order the defendant to compensate the plaintiff for losses caused by road traffic accident disabled totaling 133200.29 yuan.

Two, the case costs and other expenses are to be borne by the defendant.

Facts and reasons: 2011 year in December 6th at fourteen fifty PM, the peak in FZ9025 car driving along the Chaoyang South Street China United Property Insurance Company door Road North to South Road and pedestrian Jia Baohe (the plaintiff) traffic accidents, injuries to the plaintiff Jia Baohe. Baoding City Public Security Bureau Traffic Police Detachment of the three battalion identified, the peak in violation of "the people's Republic of China Road Traffic Safety Law" the seventieth regulation, are all the causes of the accident, all responsibility for the accident, is not responsible for the plaintiff.

The second hospital in Baoding city for the diagnosis of left ankle joint fracture dislocation (pronation external rotation Ⅳ °). After the Baoding city road accidents assessment board for ten disabled, left lower limb function loss of more than 10%. After the two operation, the foot is still not weight-bearing, need to continue treatment. Visible, the act clearly constitute an infringement of the plaintiff, and directly to the plaintiff causing personal injury and economic losses caused by the loss, including medical costs 21280.59 yuan, the peak has to pay 19000 yuan; delay costs 41367 yuan; 13800 yuan care; hospital food subsidies 1500; nutritional costs 1500 yuan to 600 yuan; wheelchair the toilet seat, copy; a camp bed, 192 yuan; identification fee 1664.8 yuan; disability compensation 36584.4 yuan; two operation costs 7000; transportation costs 500 yuan; was dependent for living expenses 16211.5 yuan; 10000 yuan for the loss of spirit, totaling 133200.29 yuan.

To sum up, the defendant to the plaintiff causing behavior not only hurt the body, brings the huge economic and mental burden, in order to safeguard the legitimate rights and interests of the plaintiff, according to "road traffic safety law", "Civil Procedure Law" provisions, bring a lawsuit to the people's court, please your court trial, convicted of such as please!

    ThisInduced

The people's Court of new urban district of Baoding City

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                                                         July 9, 2012