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Complaint – Passenger Injured – Defendant Speeding

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

CASE NUMBER:

VITONIA S.,           
 Plaintiff,

vs.

WILLIAM D.,
  Defendant.
__________________________________/

COMPLAINT

The Plaintiff, VITONIA S., sues the Defendant, WILLIAM D., 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 January 03, 2005, Defendant was the owner and operator of a motor vehicle on the Southbound Sample Road exit ramp of Interstate 95 in Broward County, Florida.

3. At that time and place, Defendant negligently operated his motor vehicle causing it to collide with the motor vehicle in which Plaintiff was a passenger in that:

  (a) Defendant struck  the vehicle in which Plaintiff was a passenger from the rear, thereby creating a presumption of negligence; and

  (b) Defendant was traveling at a speed that was unreasonable under the circumstances; and

  (c) Defendant was not paying sufficient attention resulting in his not being able to stop his vehicle prior to it colliding with the vehicle in which Plaintiff was a passenger.

4. As a result of Defendant=s negligence, Plaintiff suffered permanent bodily injury, resulting pain and suffering, disability, disfigurement, inconvenience, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care treatment and treatment, loss of earnings, loss of ability to earn money in the future and/or permanent aggravation of a previously existing condition. As the injuries are permanent, Plaintiff will suffer damages in the future.

WHEREFORE Plaintiff demands judgment against Defendant, William E. Dudiak,  for compensatory damages 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.