Damage Claim Common Pleas Court Delaware County, Ohio

Damage Claim Common Pleas Court Delaware County, Ohio 25CVC070761-Tracy Ravenscraft, Plaintiff v. Dhespina Mili Iftiu et al., Defendants; Dhespina Mili Iftiu, whose residence is unknown but whose last known address is 394 Charlescarn Drive, Powell, Ohio 43065, is hereby notified that a Complaint was filed in Delaware County, Common Pleas Court, 117 N. Union St, Delaware, OH 43015, alleging that on or about April 30, 2024, Plaintiff, Tracy Ravenscraft was operating her 2011 Honda Pilot northbound on State Route 745, Concord Township, Delaware County, Ohio. At the same time, Defendant, Dhespina Mili Iftiu, was operating her 2023 Mercedes-Benz 350 westbound on County Road 124 when she failed to yield the right of way, failed to stop at the stop sign and struck Plaintiff, Tracy Ravenscraft's vehicle. As a direct and proximate result of Defendant, Dhespina Mili Iftiu's negligence, Plaintiff, Tracy Ravenscraft sustained physical injuries which are permanent, physical pain and suffering with attendant emotional distress that she will continue to experience in the future, a permanent loss of enjoyment of life and permanent loss of ability to perform her usual functions and activities, property damage, out of pocket expenses and medical expenses which she will continue to incur in the future, and a loss of earnings and she will continue to incur a loss of earnings in the future. Plaintiff alleges all of the same negligence claims asserted against Defendant, Dhespina Mili Iftiu, against Defendants, John Does Numbers 1-8. Plaintiff also asserts a claim for Uninsured/Underinsured motorist coverage and medical payments coverage against Defendant, Western Reserve Group. Defendant, Western Reserve Group (hereinafter referred to as "Western Reserve "), conducts business in Ohio and in all of its counties, including Delaware County. Defendant, Western Reserve , has or may have an interest relating to the subject of this action as an assignor, assignee, subrogor, or subrogee, pursuant to Rule 19(A)(3) of the Ohio Rules of Civil Procedure. At all times relevant hereto, Plaintiff was insured under an automobile insurance policy issued by Defendant, Western Reserve . Their policy offered uninsured/underinsured motorist coverage and medical payments coverage. Because Plaintiff does not have an entire copy of the policy, a copy of the policy is not attached to the Complaint. This action seeks, in part, to determine the rights and responsibilities of the Parties under the Defendant, Western Reserve, policy in question. At the time of the vehicular collision described above, Plaintiff was "insured" as this term may be defined in the Defendant, Western Reserve , policy, described above. Pursuant to R.C. 3937.18, Plaintiff has complied with all of the conditions precedent to perfect an uninsured/underinsured motorist claim, and a claim for medical payments coverage against the Defendant, Western Reserve , policy described above. Plaintiff was insured under the Defendant, Western Reserve , policy and is entitled to coverage of up to the limits of uninsured/underinsured motorist coverage, and up to the limits of medical payments coverage from Defendant, Western Reserve . Plaintiff asserts a subrogation claim against Defendant, UMR. At all times relevant hereto, Plaintiff was a beneficiary under the health insurance plan issued by Defendant, UMR. Defendant, UMR, has paid medical bills for injuries sustained by Plaintiff relating to the above-mentioned April 30, 2024, motor vehicle collision involving Defendant, Dhespina Mili Inftiu. Plaintiff has complied with all of the conditions precedent for perfecting a claim or claims against the health insurance coverage provided by Defendant, UMR. Plaintiff demands judgment against Defendants in an amount in excess of $25,000.00 for damages, costs, and expenses incurred; a declaration that Plaintiff have available coverage under the Defendant, Western Reserve Group policy of, up to the limits of Uninsured/Underinsured motorist coverage and up to the limits of medical payment coverage, for declaratory relief against Defendant, UMR, with respect to Plaintiff' contractual rights under the respective health plan effective the date of the collision and for any other relief to which Plaintiff may be entitled. Defendant is further notified to answer said Complaint within twenty-eight (28) days after the last date of publication. Tom Somos, 1654 East Broad Street, Third Floor, Columbus, Ohio 43203, (614)488-2270, tsomos@somoslaw.com, Attorney for Plaintiff. This ad will run once a week for six (6) successive weeks. Service of process shall be deemed complete at the date of last publication. Very Truly Yours, Tom Somos January 31, February 7, 14, 21, 28, March 7, 2026 6T 90217656