Preview
we" CASE NUMBER: 502021CA010079XXXXMB Div: AA ****
Filing # 133399347 E-Filed 08/25/2021 02:24:28 PM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
VIOLECIA JACQUET BRUNO
Plaintiff,
Vs.
wr pearnn
DLJ. OUD
And SUMMERLAND POOLS, INC.
Defendants
/
COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL
COMES NOW the Plaintiff, VIOLECIA JACQUET BRUNO by and through her
undersigned counsel, files this, her Complaint for Damages and Demand for Jury Trial against
Defendants, ELI J. ETZLER and SUMMERLAND POOLS, INC, and states:
1. This is an action for damages exceeding $30,000.00, exclusive of costs and interest.
2. Plaintiff, VIOLECIA JACQUET BRUNO is an individual over the age of eighteen (18).
3. Defendant, ELI J. ETZLER, is an individual over the age of eighteen (18).
4. Defendant, SUMMERLAND POOLS, INC is a Florida Profit Corporation doing business
in Dalen Daach Canater
io Gumi each UGuny.
5. Venue is proper in Palm Beach County, as the cause of action accrued in Palm Beach
County.
6. The Honorable Court has jurisdiction over this cause and the parties hereto.
COUNTI
7. On or about August 29, 2017, the Defendant SUMMERLAND POOLS, INC, owned a
motor vehicle that was operated with their permission by ELI J. ETZLER at or near NE 5%
Avenue in Delray Beach, Palm Beach County.
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED NaINEINNAA NO.94.02 DNA
Pm. PAL DUA VUUINE TT, FL, JUOL IE mDNUeeY, ULLIAN, YUreui2ue |! ue.24.20 Fit8. At that time and place Defendant ELI J. ETZLER, negligently operated or maintained the
motor vehicle he was operating so as to cause a collision with a motor vehicle being driven by
Plaintiff, VIOLECIA JACQUET BRUNO.
9. That as a direct and proximate result of the negligence of the Defendant, ELI J. ETZLER,
the Plaintiff, VIOLECIA JACQUET BRUNO, has suffered bodily injury and resulting pain and
suffering, disability, loss of capacity for the enjoyment of life, expense of hospitalization,
medical and nursing care and treatment, and aggravation of a pre-existing condition. The losses
are either permanent or continuing in nature, and Plaintiff will suffer the losses in the future. In
addition, where there is no finding of permanent injury, the Plaintiff is entitled to applicable
medical expenses and lost gross income and earning capacity not payable under any personal
injury protection coverage, pursuant to Florida Statutes 627.736 (1), 627.737 (1), and 627.737
2).
COUNT IT
10. Plaintiff hereby incorporates and realleges any and all allegations contained in paragraphs
1-9, as if fully plead herein.
ii. Gn or about August 29, 2017, the Defendant SUMMERLAND POOLS, INC, owned a
motor vehicle that was operated with their permission by ELI J. ETZLER at or near NE Sth
Avenue in Delray Beach, Palm Beach County.
12. _ At that time and place Defendant ELI J. ETZLER, negligently operated or maintained the
motor vehicle he was operating so as to cause a collision with a motor vehicle being driven by
Plaintiff, VIOLECIA JACQUET BRUNO.
13. That as a direct and proximate result of the negligence of the Defendant,
STIMAAEDT ANT DAAT CO INO tha Dininiff VIAT ECTA TACATIRT RDTINA has onffarad
SUNLUYIORLAN PUULO, UNL, UIC Lidl, YIULoUIA VALU DINUINU, Has Suucrcabodily injury and resulting pain and suffering, disability, loss of capacity for the enjoyment of
life, expense of hospitalization, medical and nursing care and treatment, and aggravation of a
pre-existing condition. The losses are either permanent or continuing in nature, and Plaintiff will
suffer the losses in the future. In addition, where there is no finding of permanent injury, the
Plaintiff is entitled to applicable medical expenses and lost gross income and earning capacity
not payable under any personal injury protection coverage, pursuant to Florida Statutes 627.736
(1), 627.737 (1), and 627.737 (2).
WHEREFORE, Plaintiff demand trial by jury and judgment for compensatory damages,
costs of suit on all counts against the Defendants including but not limited to bodily injury,
disability, disfigurement and mental anguish; pain and suffering, loss of capacity for the
enjoyment of life, expenses of hospitalization, medical and nursing care and treatment, wage loss
and earning capacity loss and all other relief that is just and reasonable.
MARK JANUSCHEWSKI, P.A.
Attorneys for Plaintiff
639 E Ocean Ave
Suite 402
Boynton Beach, FL 33435
(561) 752-0309 — Phone
(561) 752-0409 — Fax
mipapleadings@gmail.com
By:__s/Mark Januschewski
AD TANTO WOT
LAIN JALNUSU TE WOKE
Florida Bar No.: 153257
Preview
we" CASE NUMBER: 502021CA010079XXXXMB Div: AA **** Filing # 133399347 E-Filed 08/25/2021 02:24:28 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA VIOLECIA JACQUET BRUNO Plaintiff, Vs. wr pearnn DLJ. OUD And SUMMERLAND POOLS, INC. Defendants / COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL COMES NOW the Plaintiff, VIOLECIA JACQUET BRUNO by and through her undersigned counsel, files this, her Complaint for Damages and Demand for Jury Trial against Defendants, ELI J. ETZLER and SUMMERLAND POOLS, INC, and states: 1. This is an action for damages exceeding $30,000.00, exclusive of costs and interest. 2. Plaintiff, VIOLECIA JACQUET BRUNO is an individual over the age of eighteen (18). 3. Defendant, ELI J. ETZLER, is an individual over the age of eighteen (18). 4. Defendant, SUMMERLAND POOLS, INC is a Florida Profit Corporation doing business in Dalen Daach Canater io Gumi each UGuny. 5. Venue is proper in Palm Beach County, as the cause of action accrued in Palm Beach County. 6. The Honorable Court has jurisdiction over this cause and the parties hereto. COUNTI 7. On or about August 29, 2017, the Defendant SUMMERLAND POOLS, INC, owned a motor vehicle that was operated with their permission by ELI J. ETZLER at or near NE 5% Avenue in Delray Beach, Palm Beach County. CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED NaINEINNAA NO.94.02 DNA Pm. PAL DUA VUUINE TT, FL, JUOL IE mDNUeeY, ULLIAN, YUreui2ue |! ue.24.20 Fit8. At that time and place Defendant ELI J. ETZLER, negligently operated or maintained the motor vehicle he was operating so as to cause a collision with a motor vehicle being driven by Plaintiff, VIOLECIA JACQUET BRUNO. 9. That as a direct and proximate result of the negligence of the Defendant, ELI J. ETZLER, the Plaintiff, VIOLECIA JACQUET BRUNO, has suffered bodily injury and resulting pain and suffering, disability, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of a pre-existing condition. The losses are either permanent or continuing in nature, and Plaintiff will suffer the losses in the future. In addition, where there is no finding of permanent injury, the Plaintiff is entitled to applicable medical expenses and lost gross income and earning capacity not payable under any personal injury protection coverage, pursuant to Florida Statutes 627.736 (1), 627.737 (1), and 627.737 2). COUNT IT 10. Plaintiff hereby incorporates and realleges any and all allegations contained in paragraphs 1-9, as if fully plead herein. ii. Gn or about August 29, 2017, the Defendant SUMMERLAND POOLS, INC, owned a motor vehicle that was operated with their permission by ELI J. ETZLER at or near NE Sth Avenue in Delray Beach, Palm Beach County. 12. _ At that time and place Defendant ELI J. ETZLER, negligently operated or maintained the motor vehicle he was operating so as to cause a collision with a motor vehicle being driven by Plaintiff, VIOLECIA JACQUET BRUNO. 13. That as a direct and proximate result of the negligence of the Defendant, STIMAAEDT ANT DAAT CO INO tha Dininiff VIAT ECTA TACATIRT RDTINA has onffarad SUNLUYIORLAN PUULO, UNL, UIC Lidl, YIULoUIA VALU DINUINU, Has Suucrcabodily injury and resulting pain and suffering, disability, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of a pre-existing condition. The losses are either permanent or continuing in nature, and Plaintiff will suffer the losses in the future. In addition, where there is no finding of permanent injury, the Plaintiff is entitled to applicable medical expenses and lost gross income and earning capacity not payable under any personal injury protection coverage, pursuant to Florida Statutes 627.736 (1), 627.737 (1), and 627.737 (2). WHEREFORE, Plaintiff demand trial by jury and judgment for compensatory damages, costs of suit on all counts against the Defendants including but not limited to bodily injury, disability, disfigurement and mental anguish; pain and suffering, loss of capacity for the enjoyment of life, expenses of hospitalization, medical and nursing care and treatment, wage loss and earning capacity loss and all other relief that is just and reasonable. MARK JANUSCHEWSKI, P.A. Attorneys for Plaintiff 639 E Ocean Ave Suite 402 Boynton Beach, FL 33435 (561) 752-0309 — Phone (561) 752-0409 — Fax mipapleadings@gmail.com By:__s/Mark Januschewski AD TANTO WOT LAIN JALNUSU TE WOKE Florida Bar No.: 153257