Home – Car Accidents – Complaint – Driving Under The Influence

Complaint-Driver Under the Influence of Alcohol,
Marijuana and/or Other Substances

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

CASE NO. xx-xxxx-xx

DONNA C.
and DONNA C., as
Guardian of DEBBIE F.,
Plaintiff,

vs.

JAMES C.,
Defendant.
__________________________/

COMPLAINT

The Plaintiff, DONNA C., and DONNA C. as Guardian of DEBBIE F.,  sues the Defendant, JAMES C., and alleges:

1.  This is an action for damages in excess of $15,000.00, exclusive of interest, costs and attorney’s fees.

2.  Plaintiff, DONNA C., is the mother of DEBBIE F., who is currently 15 years old.

3.   On or about [date], the Defendant, JAMES C., was the owner or long-term lessee of a motor vehicle and was operating it on State Road 84 in Broward County, Florida.

4.  At that time and place, Defendant, JAMES C., negligently operated his motor vehicle causing it to collide with the vehicle in which Plaintiffs were riding as passengers in that:

a.    JAMES C. failed to observe surrounding conditions; and

b.    JAMES C. was traveling at a speed which was unreasonable or excessive under the circumstances; and

c.    Supposedly, JAMES C. rear-ended the vehicle in which the Plaintiffs were traveling; and

d.    JAMES C. was driving under the influence of alcohol, marijuana and/or other  substances.

5.    As a result of the negligence of the Defendant, JAMES C., the Plaintiffs, DONNA C. and DEBBIE F., suffered permanent bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money and/or permanent aggravation of a pre-existing condition.   As the injuries are permanent, Plaintiffs, DONNA C. and DEBBIE F., will continue to suffer damages in the future.

WHEREFORE Plaintiffs, demand judgment for compensatory damages against the Defendant, JAMES C., and further demand a trial by jury of all issues so triable.

ALAN D. SACKRIN
Attorney for Plaintiffs
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
Telephone:  (954) 455-0800

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.