Several preliminary objections raised in Philadelphia car crash case

By Nicholas Malfitano | Jul 26, 2016

PHILADELPHIA – A series of preliminary objections is being contested in a Philadelphia-based car crash case in the Philadelphia County Court of Common Pleas, connected to legal sufficiency of the included claims. 

Danielle K. Rinnier filed a motion for preliminary objections on May 16, since Tina Naples’ complaint allegedly failed to explain how her injuries were incurred during the accident, or exactly how the accident in question allegedly occurred.

Rinnier added the lawsuit sets forth a case for Keystone Quality Transport, Inc.’s negligent entrustment “without alleging material facts upon which the cause of action is based," and said the same legal insufficiency applied to the transportation company’s liability under the respondeat superior theory.

Rinnier further claimed defendant Desmond Waters was not served with the complaint within 30 days of the action’s commencement and the complaint’s reinstatement. It was also pointed out Waters was not employed by Keystone Quality Transport, Inc. when the complaint was attempted to be served.

On April 30, 2014, Naples was a passenger in a motor vehicle owned by defendant Keystone Quality Transport, Inc. and being driven by defendant Waters south on Lehigh Avenue at its intersection with B Street in Philadelphia. At that time, it struck a vehicle owned and operated by Ronni Cain – who was also traveling south on Lehigh Avenue.

According to Naples’ lawsuit, the negligence of Waters and the respondeat superior theory of liability ties Keystone Quality Transport, Inc. into the matter. Therefore, the suit contains charges of negligence and negligent entrustment versus Keystone Quality Transport, Inc., negligence versus Waters and negligence versus Cain.

Naples allegedly suffered lumbar disc herniation and protrusion for several lumbar vertebrae, shoulder strain and sprain, contusions, lacerations and abrasions.

The plaintiff is seeking damages in excess of $50,000 from all defendants in this case.

The plaintiff is represented by Nicholas J. Renzi Jr. of The Pearce Law Firm, in Philadelphia.

The defendants are represented by Brian Grady and Rinnier of Grady Law Offices, plus Paul T. Bemiller of Robert J. Casey Jr. & Associates, all in Philadelphia.

Philadelphia County Court of Common Pleas case 160201422

From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at

More News

The Record Network