IN THE COURT OF COMMON PLEAS, WOOD COUNTY, OHIO CIVIL DIVISION
HANNAH VAN DORN, TREVOR JIVIDEN,
both individually and in representative capacities
of PAYTON ALASKA JIVIDEN, PAYTON
ALASKA JIVIDEN, and NASH JOLYNN-
KAYE JIVIDEN,
Plaintiffs,
Vs.
JENNIFER HOLCOMBE, LIBERTY MUTUAL
INSURANCE, SAFE AUTO,
Defendants
Civil Case No.:
COMPLANT
COMES NOW Plaintiffs, HANNAH VAN DORN and TREVOR JIVIDEN, both
individually and in representative capacities of PAYTON ALASKA JIVIDEN, PAYTON
ALASKA JIVIDEN, and NASH JOLYNN-KAYE JIVIDEN (hereinafter “Plaintiffs”) file this
civil action against the Defendants , JENNIFER HOLCOMBE, LIBERTY MUTUAL
INSURANCE, SAFE AUTO, and MELISSA STEMEN (hereinafter, “Defendants”), and hereby
alleges and states as follows:
THE PARTIES
1. Plaintiff HANNAH VAN DORN (hereinafter “Hannah”) is an adult individual
who resides at 221 N East Bradner OH 43406. Hannah is the wife of Plaintiff TREVOR
JIVIDEN and the mother of the minor children PAYTON ALASKA JIVIDEN (born 07/11/17,
2
COMPLAINT
PAYTON ALASKA JIVIDEN (born 09/15/19), and NASH JOLYNN-KAYE JIVIDEN (born
06/02/21).
2. Plaintiff TREVOR JIVIDEN (hereinafter “Trevor”) is an adult individual who
resides at 221 N East Bradner OH 43406. Trevor is the husband of Plaintiff HANNAH VAN
DORN and the father of the minor children PAYTON ALASKA JIVIDEN (born 07/11/17,
PAYTON ALASKA JIVIDEN (born 09/15/19), and NASH JOLYNN-KAYE JIVIDEN (born
06/02/21).
3. Defendant JENNIFER HOLCOMBE is an adult individual who resides at
[ENTER ADDRESS].
4. Defendant LIBERTY MUTUAL INSURANCE of address [ENTER ADDRESS],
is an insurance company. The said Defendant is the insurance for Melissa Stemen, who was the
owner of the GMC Sierra that the Plaintiffs drove on the said day, with her permission. Melissa
refused to help with insurance policy information. Liberty Mutual Insurance have insurance
coverage via UIM insurance on the policy for Ms. Stemen.
5. Defendant SAFE AUTO of address [ENTER ADDRESS], is an insurance
company. The said Defendant is an additional insurance, which was in place for the grandmother
of the minors. The minors lived with the Grandmother and were covered by default. Notably, the
grandmother, parents, and the minors all lived in same address.
JURISDICTION
6. This court has jurisdiction pursuant to Section 2305.01, which grants Courts of
Common Pleas original jurisdiction in all civil cases.
VENUE
7. Venue is proper because Plaintiff resides in this County.
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COMPLAINT
FACTS COMMON TO ALL CLAIMS
8. On or about [ENTER DATE], Plaintiffs were driving in a GMC Sierra. Defendant
Jennifer Holcombe, who was driving a Ford Flex, ran a stop sign and hit the Plaintiffs causing
the Plaintiffs’ vehicle to flip.
9. As a result of the accident, the Plaintiffs and the minors sustained the following
injuries.
Particulars of injuries
10. Plaintiff Hannah suffered multiple fractures that required reconstruction of her
right elbow, right hip, and right ankle. She underwent multiple operations and there are severe
issues that remain limiting the functioning of her arm. Notably, the Plaintiff has difficulty in the
extension and contraction of her arm, ambulation, and pain in standing and supporting her own
weight post-accident. Her ankle, hip, and elbow were also crushed by the weight of the vehicle.
11. Plaintiff Trevor suffered neck and back strain, internal bleeding, and puncture to
the bowels. He was unable to work for several weeks.
12. Payton Jividen suffered a concussion and brain injury. Mazie Jividen suffered
whiplash, and Nash Jividen suffered whiplash.
CLAIMS
13. The allegations set forth in the foregoing paragraphs are re-alleged and
incorporated herein by reference.
14. Road users have an obligation to obey all traffic laws of the State of Ohio, and to
keep other members of the public safe to the best of their abilities. Accordingly, Defendant
Jennifer Holcombe, as a road user, had a duty of care towards other road users, including the
Plaintiffs.
4
COMPLAINT
15. However, Defendant Jennifer Holcombe failed to use reasonable care when using
the road. Defendant Jennifer Holcombe breached the duty by failing to stop at the stop sign.
16. The Plaintiffs were totally at no fault, and were using the road accordingly.
17. As a result of the Defendant’s failure to stop at the stop sign, the Defendant hit the
Plaintiffs’ car, which flipped thus leading to the injuries sustained by the Plaintiffs.
18. As a direct and proximate result of the negligence and carelessness of the
Defendant, the Plaintiffs suffered injuries.
19. Plaintiff Hannah suffered multiple fractures that required reconstruction of her
right elbow, right hip, and right ankle. She underwent multiple operations and there are severe
issues that remain limiting the functioning of her arm. Notably, the Plaintiff has difficulty in the
extension and contraction of her arm, ambulation, and pain in standing and supporting her own
weight post-accident. Her ankle, hip, and elbow were also crushed by the weight of the vehicle.
20. Plaintiff Trevor suffered neck and back strain, internal bleeding, and puncture to
the bowels. He was unable to work for several weeks.
21. Payton Jividen suffered a concussion and brain injury. Mazie Jividen suffered
whiplash, and Nash Jividen suffered whiplash.
22. Had it not been for the Defendant’s negligent driving, the accident would not have
occurred, and the Plaintiffs would not have suffered the injuries.
PRAYER FOR RELIEF
WHEREFORE Plaintiff respectfully requests that the Court grant Judgment in favor of
Plaintiff, and find Defendant Jennifer Holcombe liable for negligent driving. Plaintiffs also prays
this Honorable Court to make an Order for compensatory damages in excess of $25,000 for the
5
COMPLAINT
injuries suffered by the Plaintiffs as a result of Defendant Jennifer Holcombe’s negligent driving.
Plaintiffs also pray this court grants any other Order it deems just and fit.
DATED:
Respectfully submitted,
CERTIFICATE OF SERVICE
Signature
____________________________
TREVOR JIVIDEN
Signature
____________________________
HANNAH VAN DORN
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COMPLAINT
I hereby certify that on [ENTER DATE], copies of the foregoing Complaint have been
sent to the Defendants in the following address:
[ENTER DEFENDANTS’ ADRESSES]
Signature
____________________________
TREVOR JIVIDEN
Signature
____________________________
HANNAH VAN DORN
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