Ronquez White v. Sekret N. Jones IN THE STATE COURT OF BIBB COUNTY STATE OF GEORGIA RONQUEZ WHITE, Plaintiff, Civil Action No.26SCCV101902 v. SEKRET N. JONES, Defendant. 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 Sekret N. Jones is a resident of Bibb County, Georgia; thereby subjecting him to the venue and jurisdiction of this Court. 2. On or about November 5, 2025, on Cowan Street at or near its intersection with Lexington Street in Bibb County, Georgia, Defendant Sekret N. Jones negligently operated a motor vehicle, proximately and foreseeably causing a collision with a vehicle being lawfully operated and occupied by Plaintiff. 3. Defendant Sekret N. Jones was negligent, as pled in ¶2, by failing to keep a proper lookout, failing to yield, disregarding stop sign, 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. 4. As a proximate and foreseeable result of the Defendant's negligence, Plaintiff suffered personal injuries, incurring costly medical expenses in excess of $3,000.00, as well as lost wages in excess of $1.00. 5. In addition to ¶4, Plaintiff has endured and will continue to endure pain and suffering. 6. Plaintiff has a cause of action against the Defendant for negligence and is entitled to recover from the Defendant for his past and future medical expenses, lost wages, past and future pain and suffering, and all other damages permitted by law. 7. The actions of Defendant 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 Defendant Sekret N. Jones in an amount determined by a fair and impartial jury to be adequate and just. {Signature on Following Page} Respectfully submitted this the __29th day of January , 2026. /s/ Eric Alvarez Eric J. Alvarez GA Bar No. 477573 Attorney for Plaintiff Dozier Law Firm, LLC 487 Cherry Street, Suite 100 Macon, GA 31201 P: (478) 742-8441 F: (478) 845-4838 E: eric@dozierlaw.com Service Instructions: Sekret N. Jones 4601 Sheraton Drive, Apt 122 Macon, GA 31210 IPL0353149 Jun 27,Jul 4,11,18 2026