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Complaint - Car Accident Involving Pedestrian

IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA

CASE NO.: 00xxxx (xx)

C.A.,
                 Plaintiff,
  v.

D.S., 
                 Defendant. 
___________________________________/

COMPLAINT

Plaintiff, C.S., sues the Defendants, D.S., and alleges:

1. This is an action for damages in excess of $15,000.00, exclusive of interest, costs and attorney’s fees.

2. On or about [date], the Defendant was the owner and operator of a motor vehicle in the parking lot of the Tamarac Library located at 8701 West Commercial Blvd., Tamarac, Broward County, Florida.

3. At the that time and place, Defendant negligently operated her vehicle cause it to collide with the Plaintiff who was a pedestrian in that:

    (a) Defendant failed to observe surrounding conditions; and

    (b) Defendant attempted to make a three-point turn at a location where it was dangerous to do so; and

    (c) Defendant negligently attempted to make a three-point turn; and

    (d) Defendant operated her vehicle in a careless manner.

4. As a result of the negligence of the Defendant, Plaintiff, C.A. suffered permanent bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, 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 suffer damages in the future.

WHEREFORE, Plaintiff demands judgment for damages against the Defendant 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.
Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649

By______________________________
   ALAN D. SACKRIN 
   Florida Bar No. 349070

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