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ie Case Number: CACE-19-021329 Division: 02
Filing # 97281025 E-Filed 10/15/2019 11:04:56 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL COURT IN AND FOR,
BROWARD COUNTY, FLORIDA
STEVE RAMLAL CASE NO.
FLORIDA BAR NO. 361501
Plaintiff (s),
vs.
STELLA M. CLARKE
Defendant (s)
PETTITT SITS EEEd
COMPLAINT
COMES NOW the Plaintiff, STEVE RAMLAL, and sues the Defendant, STELLA
M. CLARKE and says
1. This is an action for damages which exceeds the sum of FIFTEEN THOUSAND
($ 15,000.00) DOLLARS.
2. That at all times material hereto, Plaintiff, STEVE RAMLAL, was a resident of
Broward County, Florida and is otherwise sui juris.
3. That at all times material hereto Defendant, STELLA M. CLARKE , was a resident
of Broward County, Florida and is otherwise sui juris.
4. On or about April 18, 2019 at approximately 5:43 p.m. Defendant, PAMELA J.
BOYLAN, operated, with the express or implied consent of the Defendant, STELLA
M. CLARKE, a motor vehicle on SR 820 (Pines Boulevard) and SR 817 (University
Drive) in Pembroke Pines, Broward County, Florida.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/15/2019 11:04:54 AM.****At that time and place, PAMELA J. BOYLAN negligently operated the motor
vehicle owned and maintained by Defendant, STELLA M. CLARKE, so that it
collided with the vehicle that the Plaintiff STEVE RAMLAL was driving.
That as a direct and proximate result of the foregoing negligence, Plaintiff, STEVE
RAMLAL, suffered bodily injury and resulting pain and suffering, impairment
disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life,
expense of hospitalization, medical and nursing care and treatment, loss of earnings
in the past and loss of ability to earn money in the future. The injury to the Plaintiff
is permanent within a reasonable degree of medical probability and the Plaintiff will
continue to suffer losses in the future.
WHEREFORE, the Plaintiff, STEVE RAMLAL, sues the Defendant, STELLA M.
CLARKE for compensatory damages in an amount within the jurisdictional limits
of this Court, to wit: in excess of FIFTEEN THOUSAND (§$ 15,000.00) DOLLARS,
exclusive of interest and costs, and demands trial by jury of all issues triable as of
right by a jury.
DATED this (Ԥ day of Bekrbaar19,
Mark Schiffrin, Esq.
schiffrinlaw@bellsouth.net
4600 Sheridan Street, Suite 205
Hollywood, Florida 33021
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ie Case Number: CACE-19-021329 Division: 02 Filing # 97281025 E-Filed 10/15/2019 11:04:56 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL COURT IN AND FOR, BROWARD COUNTY, FLORIDA STEVE RAMLAL CASE NO. FLORIDA BAR NO. 361501 Plaintiff (s), vs. STELLA M. CLARKE Defendant (s) PETTITT SITS EEEd COMPLAINT COMES NOW the Plaintiff, STEVE RAMLAL, and sues the Defendant, STELLA M. CLARKE and says 1. This is an action for damages which exceeds the sum of FIFTEEN THOUSAND ($ 15,000.00) DOLLARS. 2. That at all times material hereto, Plaintiff, STEVE RAMLAL, was a resident of Broward County, Florida and is otherwise sui juris. 3. That at all times material hereto Defendant, STELLA M. CLARKE , was a resident of Broward County, Florida and is otherwise sui juris. 4. On or about April 18, 2019 at approximately 5:43 p.m. Defendant, PAMELA J. BOYLAN, operated, with the express or implied consent of the Defendant, STELLA M. CLARKE, a motor vehicle on SR 820 (Pines Boulevard) and SR 817 (University Drive) in Pembroke Pines, Broward County, Florida. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/15/2019 11:04:54 AM.****At that time and place, PAMELA J. BOYLAN negligently operated the motor vehicle owned and maintained by Defendant, STELLA M. CLARKE, so that it collided with the vehicle that the Plaintiff STEVE RAMLAL was driving. That as a direct and proximate result of the foregoing negligence, Plaintiff, STEVE RAMLAL, suffered bodily injury and resulting pain and suffering, impairment disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings in the past and loss of ability to earn money in the future. The injury to the Plaintiff is permanent within a reasonable degree of medical probability and the Plaintiff will continue to suffer losses in the future. WHEREFORE, the Plaintiff, STEVE RAMLAL, sues the Defendant, STELLA M. CLARKE for compensatory damages in an amount within the jurisdictional limits of this Court, to wit: in excess of FIFTEEN THOUSAND (§$ 15,000.00) DOLLARS, exclusive of interest and costs, and demands trial by jury of all issues triable as of right by a jury. DATED this (‘§ day of Bekrbaar19, Mark Schiffrin, Esq. schiffrinlaw@bellsouth.net 4600 Sheridan Street, Suite 205 Hollywood, Florida 33021