IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NUMBER: 00-xxxx (xx)
The Plaintiff, M.B., sues the Defendant, C.B., 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 [date], Defendant was the owner and operator of a 2007 Honda motor vehicle at or near the intersection of East Hallandale Beach Blvd. and Diplomat Parkway in Hallandale Beach, Broward County, Florida.
3. At that time and place, Defendant negligently operated her motor vehicle causing it to collide with Plaintiff, M.B., who was operating a bicycle in that:
(a) Defendant failed to yield the right of way to Plaintiff while she attempted a turn from Diplomat Parkway onto Hallandale Beach Blvd.; and
(b) Defendant failed to observe Plaintiff, a bicyclist, when she should have.
4. As a result of the negligence of the Defendant, 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. Plaintiff’s bicycle was damaged and he incurred property damage and the loss of use of the bicycle.
WHEREFORE Plaintiff demands judgment against Defendant, C.B., 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.
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649
ALAN D. SACKRIN
Florida Bar No. 349070
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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter. We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.