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Filing # 119785968 E-Filed 01/18/2021 04:03:32 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
CASE NO.:
ADALGISA ALVAREZ DE JONES,
Plaintiff,
vs.
AMRITA SINGH, and
NEELAWATTIE SINGH,
Defendants,
/
COMPLAINT
COMES NOW the Plaintiff, ADALGISA ALVAREZ DE JONES, by and through the
undersigned attorney, and sues the Defendants, AMRITA SINGH and NEELAWATTIE SINGH,
and states:
GENERAL ALLEGATIONS
1. This is an action for damages that exceeds the jurisdictional amount of this court,
exclusive of costs and attorneys’ fees.
2. Plaintiff is a resident of Marion County, Florida.
3. Defendants, AMRITA SINGH and NEELAWATTIE SINGH, are residents of
Marion County, Florida.
4. Venue is proper in Marion County because Plaintiff's causes of action accrued in
Duval County.
COUNT I -NEGLIGENCE AGAINST
DEF! T, AMRITA SINGH
5. Plaintiff repeats, re-alleges and adopts by reference all of the allegations contained
Electronically Filed Marion Case # 21CA000108AX 01/18/2021 04:03:32 PMin the foregoing paragraphs 1 through 4 as contained herein, and further alleges:
6. On or about May 3, 2019, Defendant, Amrita Singh, operated a Jeep vehicle at or
about the intersection of Bahia Road and Midway Road in Ocala, Marion County, Florida.
7. At that time and place, Plaintiff, ADALGISA ALVAREZ DE JONES, owned and
operated a Toyota vehicle.
8. At that time and place, Defendant, AMRITA SINGH, negligently operated or
maintained the motor vehicle she was driving so that it collided with Plaintiff's vehicle.
9. As a direct and proximate result of Defendant, AMRITA SINGH’s foregoing
negligence, Plaintiff suffered bodily injury and resulting pain and suffering, disability,
disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of medical care
and treatment, loss of earnings, and loss of ability to earn money and aggravation of a previously
existing condition. The losses are either permanent or continuing and Plaintiff will suffer the losses
in the future.
WHEREFORE, Plaintiff demands judgment against Defendant, AMRITA SINGH, for
compensatory damages, interest, costs, and any other relief that this court deems just and proper
and further demands trial by jury.
COUNT II — VICARIOUS LIABILITY AGAINST NEELAWATTIE SINGH
UNDER THE DANGEROUS INSTRUMENTALITY DOCTRINE
10. Plaintiff repeats, re-alleges and adopts by reference all of the allegations contained
in the foregoing paragraphs 1 through 9 as contained herein, and further alleges:
11. On or about May 3, 2019, Defendant, Amrita Singh, operated a Jeep vehicle at or
about the intersection of Bahia Road and Midway Road in Ocala, Marion County, Florida, with
the knowledge and consent of the vehicle’s owner, Defendant NEELAWATTIE SINGH.12. At that time and place, Defendant, AMRITA SINGH, negligently operated or
maintained the motor vehicle so that it collided with Plaintiffs vehicle.
13. Defendant, NEELAWATTIE SINGH, is vicariously liable for Defendant,
AMRITA SINGH’S negligence under the Dangerous Instrumentality Doctrine.
14. As a direct and proximate result of Defendant, AMRITA SINGH’S foregoing
negligence for which Defendant, NEELAWATTIE SINGH, is vicariously liable, Plaintiff suffered
bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of
capacity for the enjoyment of life, expense of medical care and treatment, loss of earnings, and
loss of ability to earn money and aggravation of a previously existing condition. The losses are
either permanent or continuing and Plaintiff will suffer the losses in the future.
WHEREFORE, Plaintiff demands judgment against Defendant, NEELAWATTIE SINGH,
for compensatory damages, interest, costs, and any other relief that this Court deems just and
proper and further demands trial by jury.
Dated this 18th day of January, 2021.
/s/ JHays Mathis, Esquire
J. HAYS MATHIS, ESQ.
Florida Bar No: 0038564
The Pendas Law Firm
3250 Beach Boulevard
Jacksonville Florida 32207
(904) 302-6739
Attorney for Plaintiff
hmathis@pendaslaw.com
tkueneman@pendaslaw.com
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Filing # 119785968 E-Filed 01/18/2021 04:03:32 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA CASE NO.: ADALGISA ALVAREZ DE JONES, Plaintiff, vs. AMRITA SINGH, and NEELAWATTIE SINGH, Defendants, / COMPLAINT COMES NOW the Plaintiff, ADALGISA ALVAREZ DE JONES, by and through the undersigned attorney, and sues the Defendants, AMRITA SINGH and NEELAWATTIE SINGH, and states: GENERAL ALLEGATIONS 1. This is an action for damages that exceeds the jurisdictional amount of this court, exclusive of costs and attorneys’ fees. 2. Plaintiff is a resident of Marion County, Florida. 3. Defendants, AMRITA SINGH and NEELAWATTIE SINGH, are residents of Marion County, Florida. 4. Venue is proper in Marion County because Plaintiff's causes of action accrued in Duval County. COUNT I -NEGLIGENCE AGAINST DEF! T, AMRITA SINGH 5. Plaintiff repeats, re-alleges and adopts by reference all of the allegations contained Electronically Filed Marion Case # 21CA000108AX 01/18/2021 04:03:32 PMin the foregoing paragraphs 1 through 4 as contained herein, and further alleges: 6. On or about May 3, 2019, Defendant, Amrita Singh, operated a Jeep vehicle at or about the intersection of Bahia Road and Midway Road in Ocala, Marion County, Florida. 7. At that time and place, Plaintiff, ADALGISA ALVAREZ DE JONES, owned and operated a Toyota vehicle. 8. At that time and place, Defendant, AMRITA SINGH, negligently operated or maintained the motor vehicle she was driving so that it collided with Plaintiff's vehicle. 9. As a direct and proximate result of Defendant, AMRITA SINGH’s foregoing negligence, Plaintiff suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of medical care and treatment, loss of earnings, and loss of ability to earn money and aggravation of a previously existing condition. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. WHEREFORE, Plaintiff demands judgment against Defendant, AMRITA SINGH, for compensatory damages, interest, costs, and any other relief that this court deems just and proper and further demands trial by jury. COUNT II — VICARIOUS LIABILITY AGAINST NEELAWATTIE SINGH UNDER THE DANGEROUS INSTRUMENTALITY DOCTRINE 10. Plaintiff repeats, re-alleges and adopts by reference all of the allegations contained in the foregoing paragraphs 1 through 9 as contained herein, and further alleges: 11. On or about May 3, 2019, Defendant, Amrita Singh, operated a Jeep vehicle at or about the intersection of Bahia Road and Midway Road in Ocala, Marion County, Florida, with the knowledge and consent of the vehicle’s owner, Defendant NEELAWATTIE SINGH.12. At that time and place, Defendant, AMRITA SINGH, negligently operated or maintained the motor vehicle so that it collided with Plaintiffs vehicle. 13. Defendant, NEELAWATTIE SINGH, is vicariously liable for Defendant, AMRITA SINGH’S negligence under the Dangerous Instrumentality Doctrine. 14. As a direct and proximate result of Defendant, AMRITA SINGH’S foregoing negligence for which Defendant, NEELAWATTIE SINGH, is vicariously liable, Plaintiff suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of medical care and treatment, loss of earnings, and loss of ability to earn money and aggravation of a previously existing condition. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. WHEREFORE, Plaintiff demands judgment against Defendant, NEELAWATTIE SINGH, for compensatory damages, interest, costs, and any other relief that this Court deems just and proper and further demands trial by jury. Dated this 18th day of January, 2021. /s/ JHays Mathis, Esquire J. HAYS MATHIS, ESQ. Florida Bar No: 0038564 The Pendas Law Firm 3250 Beach Boulevard Jacksonville Florida 32207 (904) 302-6739 Attorney for Plaintiff hmathis@pendaslaw.com tkueneman@pendaslaw.com