ABSTRACT
PARTICULARS OF NEGLIGENCE The First Defendant was negligent in that he: (a) Drove into the back of the stationary Ford Sierra. (b) Failed to keep any or any proper lookout. (c) Drove too fast. (d) Drove too close to the vehicle in front of him. (e) Failed to brake in time or at all. (f) Failed to stop, slow down, swerve, or in any other way so to
manage or control the motor lorry as to prevent the collision. 3
4. By reason of the First Defendant’s negligence, the Plaintiff, who was 26 years of age at the time of the accident, suffered personal injury, loss and damage.
