IN THE STATE COURT OF BIBB COUNTY
STATE OF GEORGIA
BRANDON GRAY,
Plaintiff, Civil Action No. 24-SCCV-098322
v.
FREDDIE TUFF,
RICKY GRIFFIN, and JOHN DOES 1-10,
Defendants.
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IN THE STATE COURT OF BIBB COUNTY
STATE OF GEORGIA
BRANDON GRAY,
Plaintiff, Civil Action No. 24-SCCV-098322
v.
FREDDIE TUFF,
RICKY GRIFFIN, and JOHN DOES 1-10,
Defendants.
AMENDED COMPLAINT FOR DAMAGES
COMES NOW, Plaintiff in the above styled action, by and through his undersigned attorneys of record, and files this Complaint for Damages, respectfully showing this Honorable Court the following:
1.
Defendant Freddie Tuff is a resident of Bibb County, Georgia; thereby subjecting {him/her} to the venue and jurisdiction of this Court.
2.
On or about February 29, 2024, on Eisenhower Parkway at or near its intersection with Houston Avenue in Bibb County, Georgia, Defendant Freddie Tuff negligently operated a motor vehicle, proximately and foreseeably causing a collision with a vehicle being lawfully operated and occupied by Plaintiff.
3.
Defendant Freddie Tuff was negligent, as pled in ¶2, by failing to keep a proper lookout, failing to yield, following too closely, failing to exercise due care while operating a motor vehicle, and by failing to obey the Uniform Rules of the Road for the State of Georgia.
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4.
Defendant Ricky Griffin was negligent, as pled in ¶2, by failing to keep a proper lookout, failing to yield, following too closely, failing to exercise due care while operating a motor vehicle, and by failing to obey the Uniform Rules of the Road for the State of Georgia.
5.
Defendant John Does 1-10 is an unknown and unidentifiable motorist subject to the venue and jurisdiction of this Court, pursuant to O.C.G.A. §33-7-11 (d)(1).
6.
As a proximate and foreseeable result of the Defendants negligence, Plaintiff suffered personal injuries, incurring costly medical expenses in excess of $6,600.00, as well as lost wages in excess of $1.00.
7.
In addition to ¶4, Plaintiff has endured and will continue to endure pain and suffering.
8.
Plaintiff has a cause of action against the Defendants for negligence and is entitled to recover from the Defendants for his past and future medical expenses, lost wages, past and future pain and suffering, and all other damages permitted by law.
9.
The actions of Defendants in failing and refusing to resolve this matter without litigation constitutes stubborn litigiousness and has caused unnecessary trouble and expense which also entitles Plaintiff to recover penalties, litigation expenses, and attorney's fees under the authority of O.C.G.A. § 13-6-11.
WHEREFORE, Plaintiff prays that he have a judgment against Defendants in an amount determined by a fair and impartial jury to be adequate and just.
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Respectfully submitted this the 21st day of October, 2025.
__________________________
Eric J. Alvarez
GA Bar No. 477573
Attorney for Plaintiff
Eric J. Alvarez, Esq.
487 Cherry Street, Suite 100
Macon, GA 31201-7972
P: (478) 742-8441
F: (478) 845-4838
E: eric@dozierlaw.com
IPL0309170
Jan 30,Feb 6,13,20 2026