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Case Number: CACE-19-024739 Division: 12
Filing # 99658921 E-Filed 12/02/2019 04:17:21 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.
NELLY ARDILA,
Plaintiff,
vs.
NEIDA COLON,
Defendant.
Se,
COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL
COMES NOW the Plaintiff, NELLY ARDILA, by and through the undersigned
counsel, sues the Defendant, NEIDA COLON, and alleges:
ALLEGATIONS COMMON TO ALL COUNTS
1. That this is an action for damages in excess of Fifteen Thousand ($15,000.00)
Dollars and within the jurisdictional limits of this Court.
2. Atall times material hereto, the Plaintiff, NELLY ARDILA, was and is a resident
of Broward County, Florida and is otherwise sui juris.
3. Atall times material herein, the Defendant, NEIDA COLON, was and is a
resident of Miami-Dade County, Florida and is otherwise sui juris.
4. On or about May 9, 2019, Defendant NEIDA COLON, was the owner and
operator of a 2000 SATURN LS1 bearing tag number JRSV56, at the intersection
of Pembroke Road and S.W. 160" Avenue, Broward County, Florida.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/02/2019 04:17:20 PM.****. Venue is proper in this County in that all of the acts complained of herein
occurred in Broward County, Florida.
COUNT I-NEGLIGENCE CLAIM OF NELLY ARDILA
. Plaintiff re-alleges and restates the allegations in paragraphs 1 through 5 as if
fully set forth herein.
. Atall times material hereto, Defendant, NEIDA COLON, had the duty to operate
and/or maintain her motor vehicle in a reasonable safe manner so that the
vehicle would not collide with any other vehicles or pedestrians.
. That on or about May 9, 2019, Defendant, NEIDA COLON, negligently operated
or maintained her motor vehicle so as to cause it to collide with the vehicle being
operated by Plaintiff, NELLY ARDILA.
. Asa direct and proximate result of the negligence of Defendant, NEIDA COLON,
the Plaintiff, NELLY ARDILA, suffered significant and severe bodily injury and
resulting pain and suffering, disability, aggravation, of pre-existing injuries,
scarring and/or disfigurement, loss of capacity for the earnings and loss of ability
to earn money in the future. The losses are either permanent or continuing in
nature and the Plaintiff, NELLY ARDILA, will suffer the losses in the future.
Plaintiffs vehicle was damaged and she lost use of it during the period required for
its repair or replacement. Additionally, Plaintiffs automobile diminished in value as
a result of said accident.WHEREFORE, the Plaintiff, NELLY ARDILA, by and through her undersigned
counsel, sues the Defendant, NEIDA COLON, an individual for a sum in excess of
Fifteen Thousand ($15,000.00) Dollars, plus all other awards available under Florida
law. The Plaintiff seeks a trial by jury.
DATED this December 2, 2019.
LAW OFFICE OF CARLOS O. GOMEZ, P.A.
Counsel for Plaintiff
102 East 49 Street
Hialeah, Florida 33013
Telephone: (305) 698-3421
Facsimile: (305) 698-1930
Primary E-mail: cogomezpa@aol.com
sandor@cogomezlaw.com
msoto@cogomezlaw.com
By: __/s/Carlos 0. Gomez
CARLOS OMAR GOMEZ
FBN: 140554
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Case Number: CACE-19-024739 Division: 12 Filing # 99658921 E-Filed 12/02/2019 04:17:21 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. NELLY ARDILA, Plaintiff, vs. NEIDA COLON, Defendant. Se, COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL COMES NOW the Plaintiff, NELLY ARDILA, by and through the undersigned counsel, sues the Defendant, NEIDA COLON, and alleges: ALLEGATIONS COMMON TO ALL COUNTS 1. That this is an action for damages in excess of Fifteen Thousand ($15,000.00) Dollars and within the jurisdictional limits of this Court. 2. Atall times material hereto, the Plaintiff, NELLY ARDILA, was and is a resident of Broward County, Florida and is otherwise sui juris. 3. Atall times material herein, the Defendant, NEIDA COLON, was and is a resident of Miami-Dade County, Florida and is otherwise sui juris. 4. On or about May 9, 2019, Defendant NEIDA COLON, was the owner and operator of a 2000 SATURN LS1 bearing tag number JRSV56, at the intersection of Pembroke Road and S.W. 160" Avenue, Broward County, Florida. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/02/2019 04:17:20 PM.****. Venue is proper in this County in that all of the acts complained of herein occurred in Broward County, Florida. COUNT I-NEGLIGENCE CLAIM OF NELLY ARDILA . Plaintiff re-alleges and restates the allegations in paragraphs 1 through 5 as if fully set forth herein. . Atall times material hereto, Defendant, NEIDA COLON, had the duty to operate and/or maintain her motor vehicle in a reasonable safe manner so that the vehicle would not collide with any other vehicles or pedestrians. . That on or about May 9, 2019, Defendant, NEIDA COLON, negligently operated or maintained her motor vehicle so as to cause it to collide with the vehicle being operated by Plaintiff, NELLY ARDILA. . Asa direct and proximate result of the negligence of Defendant, NEIDA COLON, the Plaintiff, NELLY ARDILA, suffered significant and severe bodily injury and resulting pain and suffering, disability, aggravation, of pre-existing injuries, scarring and/or disfigurement, loss of capacity for the earnings and loss of ability to earn money in the future. The losses are either permanent or continuing in nature and the Plaintiff, NELLY ARDILA, will suffer the losses in the future. Plaintiffs vehicle was damaged and she lost use of it during the period required for its repair or replacement. Additionally, Plaintiffs automobile diminished in value as a result of said accident.WHEREFORE, the Plaintiff, NELLY ARDILA, by and through her undersigned counsel, sues the Defendant, NEIDA COLON, an individual for a sum in excess of Fifteen Thousand ($15,000.00) Dollars, plus all other awards available under Florida law. The Plaintiff seeks a trial by jury. DATED this December 2, 2019. LAW OFFICE OF CARLOS O. GOMEZ, P.A. Counsel for Plaintiff 102 East 49 Street Hialeah, Florida 33013 Telephone: (305) 698-3421 Facsimile: (305) 698-1930 Primary E-mail: cogomezpa@aol.com sandor@cogomezlaw.com msoto@cogomezlaw.com By: __/s/Carlos 0. Gomez CARLOS OMAR GOMEZ FBN: 140554