1. The Plaintiff, SHELLY WILSON, (hereinafter “WILSON”), alleges that the vehicle operated by the Defendant, BRENDA JOHNSON, (hereinafter “JOHNSON”), at the time she struck the Plaintiff’s vehicle, was registered, owned, and within the control of the Defendant, PERRY FRANKLIN (“FRANKLIN”). Prior to the date of the accident, Mr. Franklin was aware that Johnson’s driver’s license was suspended, and was an otherwise incompetent driver. The Plaintiff alleges that on the day of the accident, Ms. Johnson was driving Mr. Franklin’s vehicle with the knowledge and consent of Mr. Franklin, despite the fact that he knew that Ms. Johnson was an incompetent
