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Complaint - Driver Following Too Close

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

CASE NO. xx-xxxx-xx

JEAN F.
  Plaintiff,

vs.

LORI M.,
  Defendant.
_______________________________/

COMPLAINT

    The Plaintiff, JEAN F., sues the Defendant, LORI M., 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 September 25, 2001, Defendant was the owner and operator of a motor vehicle on eastbound Atlantic Boulevard in Coconut Creek, Broward County, Florida.

3.  At that time and place, Defendant negligently operated her motor vehicle, causing it to collide with the vehicle being driven by Plaintiff in that:

  a.  Defendant negligently failed to observe surrounding conditions; and

  b.  Defendant failed to take precautions to decrease the effects of the sun; and

  c.    Defendant was traveling at a speed which was excessive under the circumstances; and

  d.    Defendant was traveling too closely behind Plaintiff’s vehicle; and

  e.     Defendant rear-ended Plaintiff’s motor vehicle, thereby creating a presumption of negligence.

4.  As a result of the negligence of the Defendant, Plaintiff 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 continue to suffer damages in the future.  

WHEREFORE Plaintiff demands judgment for compensatory damages against the Defendant and further demands a trial by jury of all issues so triable.
 
Alan D. Sackrin
Attorney for Plaintiff(s)
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL  33009
Telephone:  (954) 458-8655

By______________________________
ALAN D. SACKRIN    
Florida Bar No. 349070    

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This document is a sample lawsuit related to a specific set of facts and circumstances and should not be used or relied upon for any car accident matter. We recommend and urge you to consult with an experienced accident lawyer for professional advice as each case is unique.

 

 

 

 

 

 

 

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