This case was last updated from PACER on 10/09/2021 at 05:57:39 (UTC).

Williams v. ViacomCBS, Inc. et al

Case Summary

On September 29, 2021, Norita Williams (“Plaintiff”), represented by Jomeco L. Law of The J.L. Law Group, LLC, and Joseph Wilson of Joseph Wilson Injury Lawyers, filed a personal injury lawsuit against ViacomCBS, Inc. (“ViacomCBS”) and Kenneth Moldovan (“Moldovan”) (collectively, the “Defendants”), seeking damages and litigation expenses, including court costs and attorney’s fees, for the injuries sustained by Plaintiff, due to Defendant ViacomCBS’s alleged negligence in failing to properly train and supervise Defendant Moldovan, who collided with Plaintiff’s vehicle in the course of his employment. This case was filed in U.S. District Court in the Northern District of Georgia with Judge Mark H. Cohen presiding. 

 

In the complaint, the Plaintiff alleged that, “On or about January 13, 2020, Plaintiff Norita Williams was traveling in the third from the left lane westbound on Interstate 20 in Unincorporated Dekalb County, Georgia.” “On or about the same time, Defendant Moldovan was traveling in the first lane westbound on Interstate 20 in Dekalb County, Georgia directly behind Plaintiff.”

 

The Plaintiff further alleged that, “Plaintiff was traveling near Candler Road when Defendant Moldovan negligently, recklessly, carelessly failed to maintain his own lane and collided with Plaintiff’s vehicle.” “The negligent operation of the vehicle Defendant Moldovan was driving was the sole and proximate cause of the collision, which is the subject of this action.” 

 

The Plaintiff also alleged that, “As a result of the subject collision, Plaintiff suffered bodily injuries.” “As a result of the injuries sustained, Plaintiff had to seek medical treatment.” “At all times relevant, Plaintiff exercised due care for her own safety.”

 

The Plaintiff lists out five claims for relief. The first claim alleged is for Negligence. The second claim alleged is for Imputable Liability. The third claim alleged is for Negligent Hiring, Training and Supervision, and the fourth and fifth claims alleged are for damages. The Plaintiff also alleged that, at the time of the collision, Defendant Moldovan was an employee and agent of Defendant ViacomCBS and Defendant was driving a vehicle within the course and scope of his employment with Defendant ViacomCBS. Plaintiff further alleged that Defendant ViacomCBS is liable for the acts and omissions of Defendant Moldovan as Defendant ViacomCBS agent and employee at the time of the collision-in-suit, under the theory of respondeat superior. Plaintiff also alleged that Defendant ViacomCBS was negligent in hiring Defendant Moldovan and entrusting him to drive its vehicle, or a vehicle rented on behalf of ViacomCBS.

 

In the prayer for relief, the Plaintiff requested the Court to enter a judgment in favor of Plaintiff and against Defendants, award Plaintiff special damages for past and present medical expenses and for loss of wages and award general damages for future medical expenses, travel expenses, physical and mental pain and suffering, and loss of enjoyment of life, to be determined at trial. The Plaintiff further requested the Court to award punitive damages; litigation expenses, including court costs and attorney’s fees; and such other and further relief as this Court deems just and proper.

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    1:21-CV-04036

  • Filing Date:

    09/29/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Personal Injury - Motor Vehicle

Judge Details

Presiding Judge

Mark H. Cohen

 

Party Details

Plaintiff

Norita Williams

Defendants

Viacomcbs, Inc.

Kenneth Moldovan

Attorney/Law Firm Details

Plaintiff Attorneys

Jomeco L. Law

Attorney at The J.L. Law Group, LLC

Suite 94526, 794 Marietta Street, Nw

Atlanta, GA 30318

Joseph Wilson

Attorney at Joseph Wilson Injury Lawyers

9 Dunwoody Park, Suite 111

Dunwoody, GA 30338

 

Court Documents

#21

(#21) Initial Disclosures by Kenneth Moldovan.(Manfredi, Michael) (Entered: 11/18/2021)

#20

(#20) Initial Disclosures by ViacomCBS, Inc..(Manfredi, Michael) (Entered: 11/18/2021)

#19

(#19) SCHEDULING ORDER: re: #18 Joint Preliminary Report and Discovery Plan. Upon review of the information contained in the Joint Preliminary Report and Discovery Plan form completed and filed by the parties, the Court orders that the time limits for adding parties, amending the pleadings, filing motions, completing discovery, and discussing settlement are as set out in the Federal Rules of Civil Procedure and the Local Rules of this Court. The discovery period shall be for EIGHT (8) MONTHS, beginning THIRTY (30) DAYS after the appearance of the defendants by filing of an answer in this case. See document for further specifics. Signed by Judge Mark H. Cohen on 10/29/2021. (tmf) (Entered: 10/29/2021)

#18

(#18) JOINT PRELIMINARY REPORT AND DISCOVERY PLAN filed by Kenneth Moldovan, ViacomCBS, Inc.. (Twomey, Margaret) (Entered: 10/29/2021)

#17

(#17) CERTIFICATE OF SERVICE by ViacomCBS, Inc..(Twomey, Margaret) (Entered: 10/25/2021)

#16

(#16) Certificate of Interested Persons by ViacomCBS, Inc.. (Twomey, Margaret) (Entered: 10/25/2021)

#15

(#15) Certificate of Interested Persons by Kenneth Moldovan. (Twomey, Margaret) (Entered: 10/25/2021)

#14

(#14) ANSWER to #1 COMPLAINT with Jury Demand by Kenneth Moldovan.(Twomey, Margaret) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 10/22/2021)

#13

(#13) ANSWER to #1 COMPLAINT with Jury Demand by ViacomCBS, Inc.. Discovery ends on 3/21/2022.(Twomey, Margaret) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 10/22/2021)

#8

(#8) Notice for Leave of Absence for the following date(s): 10/13/2021 - 10/13/2021, 12/6/2021-12/21/2021, 1/17/2022-1/21/2022, 1/30/2022-2/2/2022, 3/1/2022-3/5/2022, by Joseph Wilson. (Wilson, Joseph) (Entered: 10/01/2021)

#7

#6

#5

#4

#3

#2

1 #1

Civil Cover Sheet

#1

14 More Documents Available
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Docket Entries

  • 11/18/2021
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  • Docket(#21) Initial Disclosures by Kenneth Moldovan.(Manfredi, Michael) (Entered: 11/18/2021)

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  • 11/18/2021
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  • Docket(#20) Initial Disclosures by ViacomCBS, Inc..(Manfredi, Michael) (Entered: 11/18/2021)

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  • 10/29/2021
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  • Docket(#19) SCHEDULING ORDER: re: #18 Joint Preliminary Report and Discovery Plan. Upon review of the information contained in the Joint Preliminary Report and Discovery Plan form completed and filed by the parties, the Court orders that the time limits for adding parties, amending the pleadings, filing motions, completing discovery, and discussing settlement are as set out in the Federal Rules of Civil Procedure and the Local Rules of this Court. The discovery period shall be for EIGHT (8) MONTHS, beginning THIRTY (30) DAYS after the appearance of the defendants by filing of an answer in this case. See document for further specifics. Signed by Judge Mark H. Cohen on 10/29/2021. (tmf) (Entered: 10/29/2021)

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  • 10/29/2021
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  • Docket(#18) JOINT PRELIMINARY REPORT AND DISCOVERY PLAN filed by Kenneth Moldovan, ViacomCBS, Inc.. (Twomey, Margaret) (Entered: 10/29/2021)

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  • 10/26/2021
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  • DocketClerks Notation re #15 Certificate of Interested Persons and #16 Certificate of Interested Persons reviewed by MHC. (lwb) (Entered: 10/26/2021)

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  • 10/25/2021
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  • Docket(#17) CERTIFICATE OF SERVICE by ViacomCBS, Inc..(Twomey, Margaret) (Entered: 10/25/2021)

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  • 10/25/2021
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  • Docket(#16) Certificate of Interested Persons by ViacomCBS, Inc.. (Twomey, Margaret) (Entered: 10/25/2021)

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  • 10/25/2021
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  • Docket(#15) Certificate of Interested Persons by Kenneth Moldovan. (Twomey, Margaret) (Entered: 10/25/2021)

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  • 10/22/2021
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  • Docket(#14) ANSWER to #1 COMPLAINT with Jury Demand by Kenneth Moldovan.(Twomey, Margaret) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 10/22/2021)

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  • 10/22/2021
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  • Docket(#13) ANSWER to #1 COMPLAINT with Jury Demand by ViacomCBS, Inc.. Discovery ends on 3/21/2022.(Twomey, Margaret) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 10/22/2021)

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2 More Docket Entries
  • 10/05/2021
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  • Docket(#10) Return of Service Executed by Norita Williams. All Defendants. (Wilson, Joseph) (Entered: 10/05/2021)

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  • 10/05/2021
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  • Docket(#9) AFFIDAVIT of Service for Complaint, Summons, Civil Cover Sheet, and Discovery Request , as to ViacomCBS. (Wilson, Joseph) (Entered: 10/05/2021)

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  • 10/01/2021
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  • Docket(#8) Notice for Leave of Absence for the following date(s): 10/13/2021 - 10/13/2021, 12/6/2021-12/21/2021, 1/17/2022-1/21/2022, 1/30/2022-2/2/2022, 3/1/2022-3/5/2022, by Joseph Wilson. (Wilson, Joseph) (Entered: 10/01/2021)

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  • 09/29/2021
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  • Docket(#7) Electronic Summons Issued as to Kenneth Moldovan. (vs) (Entered: 09/30/2021)

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  • 09/29/2021
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  • Docket(#6) Electronic Summons Issued as to ViacomCBS,Inc. (vs) Modified on 10/4/2021 to correct text (vs). (Entered: 09/30/2021)

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  • 09/29/2021
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  • Docket(#5) CERTIFICATE OF SERVICE of First Request for Admissions, Interrogatories and Request for Production of Documents by Norita Williams.(vs) Modified on 9/30/2021 to edit filed date(vs). (Entered: 09/30/2021)

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  • 09/29/2021
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  • Docket(#4) CERTIFICATE OF SERVICE of Plaintiff's First Interrogatories and Request for Production of Documents. by Norita Williams.(vs) (Entered: 09/30/2021)

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  • 09/29/2021
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  • Docket(#3) Expert Disclosures by Norita Williams.(vs) Modified on 9/30/2021 to edit filed date(vs). (Entered: 09/30/2021)

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  • 09/29/2021
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  • Docket(#2) Initial Disclosures by Norita Williams.(vs) Modified on 9/30/2021 to edit filed date (vs). (Entered: 09/30/2021)

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  • 09/29/2021
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  • Docket(#1) COMPLAINT with Jury Demand (Filing fee $402, receipt number AGANDC-11293675) filed by Norita Williams. (Attachments: #1 Civil Cover Sheet)(vs) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions and Pretrial Associated Forms which includes the Consent To Proceed Before U.S. Magistrate form. (Entered: 09/30/2021)

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