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$________ TOTAL Municipal Liability – Dangerous roadway – Defendant quarry repeatedly drops large amounts of gravel on road – Plaintiff motorcyclist loses control on gravel-covered manhole cover – Severe tibial fracture.

Passaic County, NJ

The plaintiff motorcyclist, in his late 50s, contended that the defendant quarry repeatedly dropped stones onto the roadway and that the defendant municipality acted in a palpably unreasonable manner in failing to take sufficient steps to rectify the difficulties. The plaintiff contended that he lost control as his motorcycle traveled over a smooth manhole cover that was covered with gravel.

The defendant quarry maintained that the gravel which caused plaintiff’s fall was not their gravel and if it was their gravel, some fell from their trucks due to the uneven nature of the roadway surface, resulting in it dropping any excess gravel, creating a dangerous condition. The municipality contended that the roadway and manhole cover were properly maintained and that the cause of the incident was the comparative negligence of the plaintiff and the gravel left by the quarry.

The plaintiff contended that the town failed to clean up and enforce its own township regulations concerning debris on roadways. It was a which came first scenario, the chicken or the egg; the truckers contended that they were dropping gravel because the road was uneven. The plaintiff would have introduced documents concerning the township’s arguments with the quarry for failure to clean up the road and even township meeting minutes where the town engineer had been in contact with the quarry to repave the road at the quarry’s expense because they were the ones who created the hazard.

The plaintiff would have stressed that a large part of the quarry’s business is repaving roads. The plaintiff would have also argued that the condition persisted because neither defendant wanted to take responsibility for the roadway repair. The plaintiff maintained that he suffered a severe tibial fracture that required surgery and which will cause permanent pain and limitations.

The plaintiff was employed as a high end security equipment technician for a private company that has a contract with the Port Authority. He was able to return to work because the Port Authority gave him an accommodation in light of his injury. The plaintiff was unable to work for approximately five months and maintained that he suffered a wage loss of approximately $________.The case settled prior to trial for $________, including $________ from each defendant.

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