Home - Car Accidents - Complaint - Lend Car to 3rd Party

Complaint-Owner Lends Car to 3rd Party
Owner and Driver Negligent

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

RB,             
Plaintiff,

vs.

CVand TV,
Defendants.
____________________________________/

COMPLAINT

The Plaintiff, RB, sues the Defendant, CVand TV, 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 3, 2003, the Defendant, Christina Vega, was the owner of a motor vehicle which was driven with her consent by Co-Defendant, TV, on Oakland Park Blvd. in Broward County, Florida.

3.    At that time and place, Defendant, TV,  negligently operated the motor vehicle causing it to collide with Plaintiff’s motor vehicle in that:

(a) Defendant was traveling at a speed that was unreasonable under the circumstance; and
(b) Defendant failed to observe surrounding conditions; and
(c) Defendant failed to have the vehicle under control; and
(d) Defendant failed to stop his vehicle before it collided with the rear of Plaintiff=s vehicle, thus creating a presumption of negligence.  

4.    As a result of Defendant, TV’s, negligence, for which Co-Defendant, Christina Vega, is liable, Plaintiff suffered permanent bodily injury, and 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 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) 458-8655
Facsimile: (954) 455-9649

By______________________________
ALAN D. SACKRIN    
Florida Bar No. 349070    

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Broward County Lawyers

(954) 458-8655