Auto Accident Complaint Personal Injury

IN THE CIRCUIT COURT OF THE17TH JUDICIAL CIRCUIT IN ANDFOR BROWARD COUNTY, FLORIDACASE NUMBER: 12-452xxxx

S.A.,          Plaintiff, vs.

C.W.,          Defendant.__________________________________/

COMPLAINT

The Plaintiff, S.A, sues the Defendant, C.W., and alleges:

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

2. On or about [date], Defendant, C.W., owned and operated a motor vehicle at or near theintersection 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 collidewith 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, S.A., suffered permanent bodily injury,resulting pain and suffering, disability, disfigurement, inconvenience, mental anguish, loss ofcapacity for the enjoyment of life, expense of hospitalization, medical and nursing caretreatment and treatment, loss of earnings, loss of ability to earn money in the future and/or apermanent aggravation of a previously existing condition. As the injuries are permanent, Plaintiffwill suffer damages in the future.

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Auto Accident Complaint Personal Injury

WHEREFORE Plaintiff demands judgment against Defendant for compensatory damages andfurther demands a trial by jury of all issues so triable.

LAW OFFICE OF ALAN D. SACKRINAttorney for Plaintiff(s)2100 East Hallandale Beach Blvd.Suite 200Hallandale Beach, FL 33009Telephone: (954) 455-0800Facsimile: (954) 455-9649

By______________________________   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 circumstancesand 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 forprofessional advice as each case is unique.

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