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XIII. <br />That as a direct and proximate result of the aforesaid negligent, careless and <br />unlawful conduct of the Defendants which caused the wrongful death of Kristin Lorenz, <br />Plaintiff has incurred damage as set forth more fully herein. <br />FIRST CAUSE OF ACTION <br />XIV. <br />For his first cause of action, Plaintiff realleges and incorporates herein the <br />allegations set forth in Paragraphs I. through XIII. <br />XV. <br />That the County was required to safely and properly design, construct, inspect, <br />restore, repair and maintain CSAH 33 and the adjacent lands in a safe condition, and to <br />utilize safe and proper guarding, barricades, traffic signals, markings and signage. <br />XVI. <br />That the County was negligent and failed to exercise due care, which negligence <br />introduced or permitted the continued existence of dangerous and unreasonably <br />hazardous conditions, and which negligence included, without limitation, the negligent <br />and improper design and construction of CSAH 33 and adjacent lands; the failure to <br />utilize safe and proper guarding and barricades along the roadway; the failure to utilize <br />safe and proper traffic signals, markings or signage; the failure to properly and safely <br />inspect, restore, repair or maintain CSAH 33 and the adjacent lands; and/or the failure <br />to comply with applicable standards, regulations or conventions pertaining to safe and <br />proper highway design, construction, inspection, restoration, repair, maintenance, or the <br />utilization of safe and proper guarding, barricades, traffic signals, markings and signage. <br />5 <br />