Complaint – Negligent Driving
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CAROLYN MARSHALL, and
SOUL’S HARVEST CHRISTIAN CENTER INC., a Florida Non Profit Corporation,
The Plaintiff, J.B., sues the Defendants, CAROLYN MARSHALL, (“MARSHALL”) and SOUL’S HARVEST CHRISTIAN CENTER INC., ( “SOUL’S HARVEST”)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 8, 2004, the Defendant, SOUL’S HARVEST, was the owner of a motor vehicle which was operated with its consent by the Co-Defendant, MARSHALL, at or near the exit ramp to the Florida Turnpike Broward County, Florida.
3. At that time and place, Defendant, MARSHALL, negligently operated the motor vehicle causing it to collide with the motor vehicle which Plaintiff was a passenger in that:
(a) Defendant, MARSHALL, was traveling at a speed that was excessive and unreasonable under the conditions; and
(b) Defendant, MARSHALL, failed to observe surrounding conditions; and
(c) Defendant, MARSHALL, failed to brake in sufficient time avoid striking Plaintiff’s in the rear, thus creating a presumption of negligence.
4. As a result of the negligence of Defendant, MARSHALL, for which the Co-Defendant, SOUL’S HARVEST, 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 Defendants for compensatory damages and further demands a trial by jury of all issues so triable. ALAN D. SACKRIN
Alan D. Sackrin
Attorney for Plaintiff(s)
2100 East Hallandale Beach Blvd.
Hallandale Beach, FL 33009
Telephone: (954) 458-8655
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.