IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. 12-xxxx-xx
D.M. and D.F., Defendants. __________________________________/
Plaintiff, A.C., by and through her undersigned counsel, sues the Defendants, D.M. and D.F., and alleges, that:
1. This is an action for damages in excess of Fifteen Thousand ($15,000.00) Dollars, exclusive of interest, costs and attorney’s fees.
2. On or about August 15, 2001, the Plaintiff was a passenger in a motor vehicle driven at or near the intersection of Sheridan Street and North 64th Avenue, in Hollywood, Broward County, Florida.
3. On that date, Defendant, D.F., was the owner of a motor vehicle driven with his consent by Co-Defendant, D.M..
4. Defendant, D.M., negligently operated the vehicle she was driving causing it to collide with the vehicle in which Plaintiff was riding in that:
a. She failed to yield the right-of-way;
b. She failed to observe surrounding conditions; and
c. She operated the vehicle at a speed which was excessive under the circumstances.
5. As a result of the negligence of the Defendant, D.M., for which Co-Defendant, D.F., is vicariously liable, A.C. sustained permanent bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, medical and nursing care and treatment, loss of earnings, loss of ability to earn money, and/or permanent aggravation of a pre-existing condition. As the injuries are permanent, Plaintiff will continue to suffer damages in the future.
WHEREFORE, Plaintiff hereby demands judgment for damages against the Defendants, and further demands a trial by jury of all issues so triable.
LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff(s)
2100 East Hallandale Beach Blvd.
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649
ALAN D. SACKRIN
Florida Bar No. 349070
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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter.
We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.