Premises Liability: Personal Injury Claim Against Pizza Hut

My question involves an injury that occurred in the state of: Maryland


I would like advice on filing a personal injury claim. I have never filed any kind of claim and do not know if I should do this on my own or if a lawyer is needed.

On May 26, I visited a local (Maryland) Pizza Hut to pick up a carry-out order of 2 large pizzas. While walking back to my car, I fell violently after catching my foot in a very deep pothole in the parking lot. The hole was large, but I could not see it at all as I was carrying those two large pizzas and the boxes blocked me from seeing anything right in front of me. I went down HARD, and was in so much pain initially that I was unable to stand at all and support my weight. I was only a few feet from my car, but I could not get up. A fellow customer (who saw me fall) rushed over and helped to support me so I could get inside my vehicle. I was in a lot of pain and sobbing, but after I calmed down, I called the pizza hut (I could not walk to go back in) and after waiting for 20 minutes or so, someone finally came out and gave me a 1-800 number to call if I had any later problems. She said they were out of the "incident reports" she needed to make a report herself, but she wrote down her name (she was assistant manager) and store number and date and the number to call.

I drove home to put ice on my ankle, but it was so injured I could not walk on it, so my husband drove me right away to Patient First clinic for x-rays. The doctor there told me I had a severe tear to a ligament and gave me crutches and one of those inflatable shoes to support it. He told me it might take as long as 4 months to heal.

It is now about a month later and I can walk on the foot, even without the crutches and shoe, but every night, the top of the foot aches and aches and I have a hard time falling asleep because of the constant dull aching. I have been told by others who suffered severe ankle sprains and severely torn ligaments that it might never be the same and the aching might be chronic.

I need to see a specialist to see if anything more can be done, besides taking Advil constantly, to alleviate the aching. I feel Pizza Hut should cover this. I already had to pay to go to Patient First that night for the x-rays, crutches, and shoe (my co-pay was $40, but there might be more that insurance won't cover later). I do not feel I should have to pay for a specialist too. I think Pizza Hut should cover that, and also should pay a bit for pain and suffering, because there was (and is) quite of bit of that. I had to hobble around on crutches wearing that uncomfortable inflatable shoe for weeks. Now, I am out of the shoe and off the crutches, but I still have pain when I walk on it, still cannot walk far without aching pain, and feel aching all night as I lie in bed.

I feel Pizza Hut is at fault for allowing a pot hole of that size to lay open in their packing lot, knowing that their customers are often carrying giant pizza boxes out of their place and unable to see past the boxes. This happened late May and most pot holes develop in winter, so I suspect that hole was there for a long time before I fell into it. It was a deep, large hole that should have been fixed and was not.

I have pics of the hole, pics of my severely purple and swollen foot, the Patient First receipt showing my diagnosis of a sprained/ torn ligament, the name and number of the young man who had to help me stand and get into my car, and the handwritten name of the assistant manager giving me the 1-800 number to call.

I did not call that number yet, because I wanted to see if the ankle would heal quickly and be something minor or if it would be something worse. I believe it is not terribly minor at this point, as one month later I am still suffering from pain and unable to walk for long on it. So I would like to file a personal injury claim. Any advice? What should be my first step? How do I pick a lawyer? I feel overwhelmed trying to choose one when I have no information on how much I should expect them to charge or what their fee should be, or how good they are. Should I call Pizza Hut myself and try to purse this without a lawyer? Is a lawyer necessary for a small claim like this?

Any information or help is appreciated, even if it is just to suggest the smartest way to go about finding a reputable and competent lawyer.

Premises Liability: Personal Injury Claim Against Pizza Hut

Registering a Vehicle: Driving with "Incomplete Registration"

My question involves vehicle registration or title in the state of: California

My vehicle registration expires on 6/30. This year a smog check is required. I have no reason to suspect that my vehicle will not pass. It always has.

However, I am in the hospital currently and cannot smog check the vehicle for several weeks. I paid the registration fee this morning online at the DMV's website.

I was told that I would receive a notice from the DMV in a few weeks with further instructions. According to my online research, all I have to do is have the car smog checked and then when the DMV receives the electronic submission from the testing station, they will mail me the stickers as they always have. All well and good.

However, what about driving in the interim? I found several stories online from people who were cited by officers for "expired registration," a few even stating that they ended up in court.

From my reading of the vehicle code, it is allowable to drive with an "incomplete registration":

4606. Notwithstanding any provision of subdivision (a) of Section 5204 to the contrary, when an application for the registration of a vehicle has been made as required in Sections 4152.5 and 4602, the vehicle may be operated on the highways until the new indicia of current registration have been received from the department, upon condition that there be displayed on the vehicle the license plates and validating devices, if any, issued to the vehicle for the previous registration year.

Am I wrong about this? Obviously the car has to be smog checked to complete the registration, and I as long as I do so as soon as I am able, it ought to be fine, yes?

Registering a Vehicle: Driving with "Incomplete Registration"

Trade-Ins: Dealer Error Processing a Traded-In Leased Vehicle

My question involves a consumer law issue in the State of: Alabama

I have a question in regards to a vehicle lease. October of last year my husband and I traded in our leased vehicle for another lease through a local Chevrolet dealership. After returning the lease the dealership did not do the proper paperwork and somehow the leased trade-in was towed. We were informed of this a month later when the towing company sent us a bill for the tow as well as the storage of the vehicle. At that time we began a dispute with the dealership and after multiple phone calls and face to face correspondence they "ensured" us that it was handled. Around January of this year we began receiving outstanding balances from Ally the financial institute who we had the lease through. They told us to send over insurance paperwork showing the change of coverage (in Oct.) which would put liability back on the dealership therefore, taking us out of the equation. All of this to say we are still disputing this with Ally after sending the documentation multiple times (I have documentation of this) and taking a hard hit to our credit (another thing they said they would come correct on). I feel as if we are going to have to take a legal stance if this is not corrected asap. My questions are how would we go about this and is this a legitimate case? Also, is there any repercussion for running my husbands pristine credit way down for such an extended period of time when we are not at fault?

Trade-Ins: Dealer Error Processing a Traded-In Leased Vehicle

Traffic Accidents: Claiming Compensation for a Back Injury After a Car Accident

My question involves an injury that occurred in the state of: California

Rear ended while stopped at a traffic light. Other driver has same insurance company as myself. I have back pain and damage to rear of new truck. Headed to personal doctor today and apt for truck estimate. What other steps do I need to take for injury claim and compensation? How easily will they settle as other driver is from same insurance company? advise?

Traffic Accidents: Claiming Compensation for a Back Injury After a Car Accident

Relocation: Relocation of Minor Children to Another State from Kansas

My question involves a child custody case from the State of: KS

I am wondering how the state of Kansas feels about move-away cases. I see the California is move-away friendly and various other states, but I cannot find anything on Kansas. I can prove the move out of Kansas to be beneficial to the child but my child's mother has done the bare minimum in regards to parenting. Will they consider what would happen if the child was left here with non-custodial parent who works part-time, drinks a lot and has no driver's license? All of my extended family is in the state we wish to move. Will they give weight to that?

Another question, my child's mother stated in her motion to prevent me from moving, that she has been involved in school and various activities. She absolutely has not and I have photos that she wasn't there and they can talk to the teachers. How can she lie on a court document and how can i prove it??

Relocation: Relocation of Minor Children to Another State from Kansas

Traffic Lane Violations: Fighting a Ticket for Driving on the Wrong Side of the Road, VC 21650

My question involves a traffic ticket from the state of: California

I was cited for traffic code 21650 violation - Driving on the wrong side
I seek your advice as to how much merit my case has and how I should fight the case- In person or by written trial

Here is description of the event-
It was about 7:30 PM in May and I was driving on a surface street and there was very less traffic on either sides.
As I was driving I noticed that ahead of me my side of the street was blocked by a police car with flashing lights.
There was no traffic coming from the other side. There was no cop to guide the traffic. But I saw a cop standing in the middle of the other side of the street.
I did not know where I was supposed to go. I slowed to down to 5 miles per hour and went close to the cop to ask for direction as where I was supposed to go. As soon as the cop saw me he said " you are on the wrong side of the street and I will have to site you a ticket".
He was not in the mood to listen to anything I would say. I was pulled over and cited a ticket.


After a few minutes of being pulled over and while i was waiting in my car- I noticed that there were some cars driving on the same side as I was and did exactly what I did - slowed down and try to come to the cop to ask where should they go thinking that the traffic was being diverted.
The cop did not give ticket to any of those drivers and let them go with a warning.

I noticed that the reason there was no oncoming traffic was that at say 100 feet distance from where the cop was standing the other side of the street was also blocked.
I then noticed that there might have been an accident before at the location and cops where there to investigate.


Now as per the code 21650 (F)-
21650. Upon all highways, a vehicle shall be driven upon the right
half of the roadway, except as follows:
(F) When the vehicle is necessarily traveling so slowly as to
impede the normal movement of traffic, that portion of the highway
adjacent to the right edge of the roadway may be utilized temporarily
when in a condition permitting safe operation.

Can I use this part of the code in my defense? I want to give a fight to this ticket. I am also open to arguing in person before the judge or to a written trial.

This is my first ever ticket in 13 years of driving in the USA and I really don't think I made any mistake in this case. I did not put anyone's life in danger; I was driving at 5 miles per hours and my intention was only to ask the cop where I am supposed to go.

Please advice.

Traffic Lane Violations: Fighting a Ticket for Driving on the Wrong Side of the Road, VC 21650

Traffic Accidents: Can an Injured Driver File One Lawsuit for Two Separate Accidents

My question involves an injury that occurred in the state of: WA

A driver who has a history of distracted driving gets in a MVA that they may or may not have been able to avoid depending on their driving style.
They are taken to ER and no notable or significant injuries are found but six months later they sue insured other driver for claimed lower back injury that may or may not have been pre-existing, plus loss of consortium (55 yr old woman claims used to have intercourse seven days per week), etc, etc.
Defendant's auto insurance assigns contracted counsel who barely pays attention to case and it drags on to within one week of SOL running out (defendant was never legally served).

Plaintiff counsel then moves at the brink of SOL for dismissal of defendant without prejudice and at the same time files another P.I. suit introducing a co-defendant. Apparently a year and a half after the first accident Plaintiff had gotten into another MVA. Her same counsel combines both defendants into one lawsuit. That defendant was more likely the at-fault driver in that accident and the suit is for aggravation of alleged injuries from first accident plus alleged carpal-tunnel syndrome acquired from the second. Case is set for arbitration ($50K damage limit in WA) until Plaintiff counsel realizes that added defendant's policy has $100K limit and suddenly plaintiff's injuries from second accident get worse (big surprise). Case is switched to request for jury trial. It then drags on and on with multiple verbal promises of moving along by Plaintiff counsel that never materialize. Contracted counsel for first defendant is so lackadaisical he doesn't take the time to copy his client multiple case filings. Four years after the lawsuit was filed against his client he has never even met with him. Defendant's insurance policy premiums were paid on time for 30 years and had no significant accident hx or claims filed ("US**, "We Know What It's Like to Serve". Now I know what it is they serve).

That is the four year background of the case; now the Question:
Given that initial Defendant counsel does not seem to care or is incompetent and subsequent co-defendant has a reputable legal firm representing them, can initial defendant discuss the case (off the record) with that counsel? Issues would be: Plaintiff stated upon deposition that she had never been arrested, yet she was arrested for DUI in past and has case #/conviction; Plaintiff has been ticketed for distracted driving: speeding while on cell phone; WSP once issued a speeding ticket to her for 13 mph-over after pacing her for over a mile right along side of her while she was absentmindedly occupying the left lane. It seems like a better driver might also not be so accident-prone. There are also multiple misstatements of fact in the record pertaining to the first accident, plus the primary Plaintiff witness is an incarcerated felon of questionable reliability and truthfulness established in his past Court records. The accident report has damage drawn on the wrong end of the car and the officer/badge is converted to the wrong Police Department somewhere along the course of the record. There is more (like indications that Plaintiff has opioid-seeking tendencies in pharmacy records) but I doubt any of this has been conveyed to co-defendant's counsel. It seems to me that there is a common interest for both co-defendants that, if made evident to the Court, a high dollar award is on shaky ground given all of the loose ends. It should never been moved up from Arbitration. Can initial defendant share this info with co-defendant's counsel?

I can't help but wonder: is there a conflict of interest somehow since US** is initial defendant's policy for liability and plaintiff also has US** for under-insured motorists if defendant's limits are exceeded; why wouldn't they assign more effective counsel?? Are they sand-bagging to drive defendant to seek competent counsel on their own? They have repeatedly stated verbally that initial defendant will be settled for their limits and no more, but representation on both sides has not been trustworthy.

I apologize for the long-winded post, but date of the first MVA was in 2011. Now within past two weeks Plaintiff counsel is Judge-shopping. No details re his justification for Affidavit of Prejudice; but why did he wait to prolong Settlement Conference scheduling until just now? I have heard that dragging a P.I. case out for a long time tends to add some perceived or virtual credibility to the claim. What are we waiting for, plaintiff's next MVA to tag on another defendant?

We are on fixed income, so our US** coverage is our only hope. No, I am not going to waste my time with a Bar complaint and in reality there is no such thing as legal malpractice. It is a "don't bite the hand that feeds" situation.

Traffic Accidents: Can an Injured Driver File One Lawsuit for Two Separate Accidents