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Complaint - Plaintiff Rear Ended

IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NUMBER: 00-356xxxx

R.A., 
          Plaintiff,
 vs.

L.W.,
          Defendant.
__________________________________/

COMPLAINT

The Plaintiff, R.A, sues the Defendant, L.W., and alleges:

1. This is an action for damages that exceeds $15,000.00, exclusive of interest, costs, and attorney's fees.

2. On or about [date], Defendant, L.W., owned and operated a motor vehicle at or near the intersection of University Drive and Ramblewood Road in Coral Springs, Broward County, Florida.

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

(a) Defendant failed to pay sufficient attention to avoid the collision; and

(b) Defendant failed to yield the right of way; and

(c) Defendant traveled at a speed which was unreasonable under the circumstances; and

(d) Defendant failed to obey traffic control devices; and

(e) Defendant rear-ended Plaintiff’s vehicle creating a presumption of negligence.

4. As a result of the Defendant's negligence, Plaintiff, R.A., 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 a 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 for compensatory damages 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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