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: 03-xxxx-xx CA (xx) Plaintiff, vs. JERRUS ENTERPRISES, INC., and M.J.F., Defendants. __________________________/ AMENDED COMPLAINT The Plaintiff, Y.R.C., sues the Defendants, JERRUS ENTERPRISES, INC., and MARCO TULIO M.J.F., and files this Amended Complaint and alleges: 1. This is an action for damages in excess of $15,000.00, exclusive of interest, costs and attorneys fees. 2. On or about November 13, 2002, Defendant, JERRUS ENTERPRISES, INC., was the owner of a motor vehicle which was driven by one of its employees, Co-Defendant, M.J.F. while in the course and scope of his employment with JERRUS at or near the intersection of Ives Dairy Road and Northeast 15 Court in Miami-Dade County, Florida. 3. At that time and place, Defendant, M.J.F., negligently operated the motor

vehicle he was driving causing it to collide with Plaintiffs motor vehicle in that: a. M.J.F. attempted to change lanes when it was not reasonably safe to do so; and b. M.J.F. failed to yield the right of way to Plaintiff; and c. M.J.F. failed to observe surrounding conditions; and d. M.J.F. was too inexperienced to operate the vehicle he was driving and he did not possess the appropriate drivers license to

Cohen vs. Jerrus Enterprises, Inc.

operate it. 4. As a result of the negligence of the Defendant, M.J.F., for which

Co-Defendant, JERRUS ENTERPRISES, INC., is liable, Plaintiff suffered permanent bodily injury and resulting pain and suffering, disability, physical impairment, 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, Plaintiff, Y.R.C., will continue to suffer damages in the future. Plaintiffs automobile was damaged which Plaintiff paid to repair; the vehicle lost value and Plaintiff lost the use of the vehicle during the period required for its repair or replacement. WHEREFORE Plaintiff demands judgment for compensatory damages against the Defendant and further demands a trial by jury of all issues so triable. LAW OFFICE OF ALAN D. SACKRIN Attorney for Plaintiff 2100 East Hallandale Beach Blvd. Suite 200 Hallandale Beach, FL 33009 Telephone: (954) 455-0800 By______________________________ ALAN D. SACKRIN Florida Bar No. 349070 /kb

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