Vicki Teresa Stephens v. LaMicheal Turner

IN THE DISTRICT COURT OF OKLAHOMA COUNTY, STATE OF OKLAHOMA VICKI TERESA STEPHENS, Plaintiff, vs. LAMICHEAL TURNER, Defendant. PETITION COMES NOW, VICKI TERESA STEPHENS, an individual, and Plaintiff in the above styled and captioned cause, by and through the undersigned counsel, and for her Petition against the Defendant, LAMICHEAL TURNER, alleges and states as follows: THE PARTIES 1. Plaintiff, Vicki Teresa Stephens (hereinafter “Plaintiff” or “Ms. Stephens”), at all times relevant and material to this litigation was an individual residing in Oklahoma City, Oklahoma, County of Oklahoma, State of Oklahoma. 2. Defendant, LaMicheal Turner (hereinafter “Defendant” or “Turner”) is an individual whose residence, for all material time herein, was in Oklahoma City, Oklahoma, the County of Oklahoma, State of Oklahoma. Turner was the driver of the vehicle involved in the automobile collision which is the subject of this Petition. VENUE AND JURISDICTION 3. All the acts and events material to this Petition occurred in Oklahoma County, State of Oklahoma and this matter arises out of violations of laws and statute in the State of Oklahoma. STATEMENT OF MATERIAL FACTS 4. On February 15, 2026, Plaintiff was operating her vehicle, a 2023 Nissan Rogue, heading northbound on Pennsylvania, in Oklahoma City, Oklahoma, lawfully occupying the left/inner lane. 5. At all material times, Plaintiff was wearing her seatbelt and was properly restrained while motoring her vehicle, and otherwise was alert and obeying moving traffic laws. 6. Defendant Turner was, on this same day and time, driving his vehicle, a gray 2006 Ford Taurus, having an identifying tag number of NYJ500. Mr. Turner was driving northbound on Pennsylvania Avenue in the right/outer lane. 7. Defendant Turner failed to properly observe traffic, and improperly changed lanes, striking Plaintiff and causing significant property damage to her vehicle and personal injury to the body of Plaintiff. 8. The impact of the collision caused, inter alia, Plaintiff to suffer injury to her neck, back and shoulders, and severe headache. 9. At the time of the collision, the weather conditions were clear and the roadway was dry, neither being conditions which contributed to the collision. 10. Turner failed to obey traffic laws, contributing to the negligence resulting in the collision and injuries to our client. 11. Following the accident, Ms. Stephens began to experience severe pain and numbness. She was examined and treated by experienced medical personnel who concluded Plaintiff suffered multiple injuries. 12. Because of the severity of the collision and the extent of damages to her person, Ms. Stephens was required to undergo extensive physical therapy in order to address the serious medical condition and injuries to her person. 13. The injuries sustained by Plaintiff as a result of the collision were severe and permanent in nature. 14. Plaintiff at all times did nothing to contribute to the injuries sustained and was, at all times, reasonable and conducted herself in a manner consistent with the laws of the State of Oklahoma. FIRST CAUSE OF ACTION-NEGLIGENCE Plaintiff, for her first cause of action, hereby incorporates the allegations stated in paragraphs one (1) through fourteen (14) above as if fully stated herein and incorporates the same by reference, and further alleges and states: 15. Defendant Turner was careless, reckless, negligent and negligent per se in the operation of his motor vehicle in one or more of the following respects: a. Failure to yield and keep a proper lookout for Plaintiff while operating his vehicle on the public roads; b. Failing to operate his vehicle in a prudent manner so as to avoid collision and ultimately causing injury to Plaintiff; c. Failing to exercise the degree of care required of a reasonably prudent person under similar circumstances to avoid bodily injury and damages to property; e. Failing to devote his full time and attention to driving, and maintain an appropriate lookout for traffic conditions while operating a motor vehicle, resulting in the injuries sustained by Plaintiff; and f. Failure to take appropriate and reasonable action and exercise care in operating of his vehicle so as to avoid the collisions. 16. As a direct and proximate result of Defendant Turner’s negligence, as hereinabove described, Plaintiff suffered injuries and damages which Defendant must be held liable in an amount which exceeds $10,000 and which actual sum and total damages amount Plaintiff will provide such proof as necessary at the trial in this matter. SECOND CAUSE OF ACTION Negligence-Per Se Plaintiff, for her second cause of action against Defendant, hereby incorporates the allegations stated in paragraphs one (1) through sixteen (16) above as if fully stated herein and incorporates the same by reference, and further alleges and states: 17. Defendant’s acts and conduct in the operation of his motor vehicle was reckless and careless so as to be deemed having operated the same in a wanton manner without regard for the safety of persons or property of others. 18. Oklahoma statutes specifically proscribe and prohibit operating a motor vehicle in the manner in which Defendant so operated his vehicle, thus causing the bodily injuries to Plaintiff, for which Defendant is liable. 19. Defendant’s breach of his duty to abide by the laws of the State of Oklahoma in the operation of his vehicle caused severe injuries to be sustained by Plaintiff, for which Defendant should be held liable at law. 20. Defendant is accordingly liable per se for the damages caused to Plaintiff in an amount in excess of $10,000 and which sum, and total damages amounts Plaintiff will provide such proof as necessary at the trial in this matter. THIRD CAUSE OF ACTION Negligent Infliction of Emotional Distress Plaintiff, for her third cause of action, hereby incorporates the allegations stated in paragraphs one (1) through twenty (20) above as if fully stated herein and incorporates the same by reference, and further alleges and states: 21. Plaintiff was damaged by the acts, conduct, omissions and failures of Defendant. As a direct result of injuries sustained by such negligence, Plaintiff suffered and continues to suffer, severe mental anguish, distress, mental and physical pain, psychological stress, loss of capacity and has (and will continue to incur) incurred medical expenses and distress. 22. Plaintiff's past, current and future emotional distress was and is directly caused by Defendant’s negligence and Plaintiff will suffer damages thereof in an amount in excess of $10,000 and which sum, and total damages amount Plaintiff will provide such proof as necessary at the trial in this matter. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against the Defendant on her First, Second, and Third causes of action in an amount in excess of $10,000 for each cause, together with recovery of a reasonable attorney fee and costs of proceeding with this action, with interest from date of judgment, and for such other and further relief as may be available in law and equity. Plaintiff further hereby reserves the right to amend this Petition. Respectfully submitted, [Signature] Ge’Andra D. Johnson OBA# 32810 Johnson Legal, P.L.L.C. 6303 North Portland Avenue, Suite 305 Oklahoma City, Oklahoma 73112 (405) 648-5273 (telephone) (405) 673-7322 (facsimile) [email protected] ATTORNEYS FOR PLAINTIFF VICKI TERESA STEPHENS JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that on this 13th day of February 2026, a true and correct copy of the above Answer and Counterclaim was placed in the United States Mail, postage prepaid certified, and addressed to the following: LaMicheal Turner 2015 NW 19th Street Oklahoma City, Oklahoma 73106 Ge’Andra D. Johnson