June is driving home on January 10 of this year and comes to a stop at a red light at an intersection in the Town of Lucy, Barnes County, State of Placid.

June is driving home on January 10 of this year and comes to a stop at a red light at an intersection in the Town of Lucy, Barnes County, State of Placid. She is on State Street. The intersecting road is called Dellinger Boulevard. As she waits for the light to turn green, a 2002 Ford Explorer SUV driven by Randy Reckless approaches from the east on Dellinger Boulevard and runs the red light. June, who sees that the light in her direction has turned green, begins to accelerate and reaches the intersection just as Randy Reckless runs the red light. Randy’s vehicle slams into June’s car on the driver’s side. June is pinned inside the car, and it takes over two hours to get her out. When the local fire department finally frees her, they discover that June has numerous broken bones and internal injuries. Police cite Randy for failing to stop at the red light, failure to yield, and reckless driving. 

Assignment:

Draft a complaint based on these facts and pay particular attention to your allegation of proximate cause. How do you allege proximate cause under these facts?