DIEGO VELASQUEZ VS TERRELL L OWENS ET AL (2024)

6. The Plaintiff has retained his undersigned attorneys and has agreed to pay them a reasonable fee for his services herein.

7. This accident occurred on June 10, 2020 , in Miami-Dade County, Florida.

8. PLAINTIFF was operating a 2013 Honda Civic 2D and was wearing his seatbelt/shoulder harness.

9. At that said time and place, OWENS, was operating a 2018 Mercedes Benz GLS 450, owned by the PV.

10. OWENS was traveling eastbound on SW 24 street.

11. OWENS, improperly changed lanes striking the vehicle PLAINTIFF was traveling in.

(TERRELL L OWENS)

12. PLAINTIFF re-alleges and incorporates by reference the allegations made in paragraphs 1 through 11 of its Complaint as is fully set forth herein.

13. On the occasion in question, OWENS was negligent in the following particulars:

A. Careless Driving

B. Improper lane change.

14. As a direct and proximate result of the negligent and careless manner in which OWENS operated the vehicle, the ensuing crash caused PLAINTIFF, to be jolted and forcefully thrown against the interior of the vehicle, resulting in pain to his body.

15. As a direct and proximate result of the OWENS's negligence, PLAINTIFF suffered 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

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treatment, loss of earnings, and loss of ability to earn money. The losses are either permanent or continuing and will suffer the losses in the future.

16. PLAINTIFF injuries and damages were sustained as a proximate consequence of the negligence of OWENS, who carelessly and improperly caused his vehicle to collide with PLAINTIFF'S automobile, which he was driving at the time of the collision.

17. PLAINTIFF has incurred or in the future will incur expenses in excess of $50,000.00, exclusive of hospital expenses, x-rays, and other diagnostic medical expenses.

WHEREFORE, the PLAINTIFF demands judgment against YUSLAY in excess of Fifty Thousand Dollars (50,000.00), for compensatory damages, costs, pre-judgment interest on liquidated damages, and reasonable attorneys' fees and any other awards this Court deems equitable and just.

(PV HOLDING CORP)

18. PLAINTIFF re-alleges and incorporates by reference the allegations made in paragraphs 1 through 11 of its Complaint as is fully set forth herein.

19. On the occasion in question, PV was negligent in the following particulars:

A. Defendant, PV, failed to carefully provide the use of its motor vehicle.

20. As a direct and proximate result of the negligent and careless manner in which the Defendant, OWENS, operated the vehicle, the ensuing crash caused Plaintiffs to be jolted and forcefully thrown within her vehicle, resulting in immediate pain and trauma to her body for which Defendant, PV, is vicariously liable.

21. As a direct and proximate result of the Defendant's, PV, negligence Plaintiff

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Brinkley, Tanya

Party Details

Velasquez, Diego

Owens, Terrell L

PV Holding Corp

Reyes, Adrian

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