Preview
wes CASE NUMBER: 502018CA015498XXXXMB Division: AD ****
Filing # 81880695 E-Filed 12/10/2018 02:40:07 PM
IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
Case No.:
Div.:
ERROLL INNISS,
vs.
THE FLORIDA HIGHWAY PATROL,
A division of FLORIDA DEPARTMENT OF HIGHWAY
SAFETY & MOTOR VEHICLES, an Agency of the
State of Florida, and
TROOPER RICKY LEE MAYO,
Defendants.
/
COMPLAINT
COME(S) NOW, the Plaintiff, ERROLL INNISS (hereinafter “Plaintiff”), by and through
the undersigned counsel and sue the Defendant(s), THE FLORIDA HIGHWAY PATROL, A
division of FLORIDA DEPARTMENT OF HIGHWAY SAFETY & MOTOR VEHICLES, an
Agency of the State of Florida (hereinafter “FHP”) and TROOPER RICKY LEE MAYO
(hereinafter “MAYO”) and in support thereof states as follows:
JURISDICTION & GENERAL ALLEGATIONS
1. That the instant action is for money damages in excess of Fifteen Thousand Dollars
($15,000.00) and meets the jurisdictional limits of this court.
2. That at all times material hereto, the Plaintiff was and is located in Palm Beach
County, Florida.
3. At all times material hereto, FHP was and is located in Leon County, Florida and
maintains offices in Paim Beach County, Fiorida.
CHEN. DAIAARCACUAAIINTY Cl CUADAND ANAFY FLEDY 491N1INN1a N9-AN-N7 DAA
PILL. PALE BLAU VUUINE TT, PL, OHI. DUUN, ULL, 1errureuiu ue.tu.ur ive4. That at all times material hereto, Defendant, MAYO, was and is a resident of
Hillsborough County, Florida and is otherwise sui juris.
5. That at all times material hereto, all actions relevant hereto took place in Palm Beach
County, Florida.
6. On or about April 18, 2016, Defendant, FHP owned a 2012 Dodge Charger bearing
license plate number: FHP113 with VIN: 2C3CDXAT1CH226605 (hereinafter the “Auto”).
7. On or about April 18, 2016, Defendant, MAYO was employed by Defendant, FHP
and was the driver of the Auto.
8. On or about April 18, 2016, Plaintiff was the driver of a 2006 GMC Envoy headed
northbound on State Road 7 (US 441) near the Old Hammock Way Intersection in Royal Palm Beach,
Palm Beach County, Florida.
9. At said time and place, Defendant, MAYO, also headed northbound on State Road
7 (US 441) near the Old Hammock Way Intersection in Royal Palm Beach, Palm Beach County,
Florida, collided with the vehicle in which Plaintiff was driving.
10. Venue is proper in Palm Beach County because the acts and omissions referred to
herein occurred in Palm Beach County, Fiorida and FHP maintains business offices in Paim Beach
County, Florida.
ll. On or about September 26, 2016, Plaintiff served written notice of the claim upon
Defendant, FHP by certified mail, return receipt requested in accordance with §768.28, Fla. Stat.
Defendant, FHP received this notice on January 17, 2017. A true and correct copy of the notice
and return receipt is attached as Exhibit “A” and incorporated herein by reference.
12. Defendant, FHP has denied Plaintiff's claims.
12 Darvon. at tn 814999 Dlasida Gtatutac Dafandant ELID has wroived savaraian
19 ruisualt Wy 00.20, Pi0liGa Siauws, VeciGain, ri as Waiveu Sovereign
Page 2 of 7immunity for this cause of action.
14. All conditions precedent to bringing this cause of action have occurred, or have
been performed, excused, discharged, satisfied or waived.
COUNTI
PLAINTIFF’S CLAIM FOR
NEGLIGENCE AGAINST DEFENDANT, FHP
15. Plaintiff adopts by reference paragraphs | through 14 above by reference as though
fully set forth herein.
16. On April 18, 2016, the Defendant, FHP, owned the “Auto”.
17. On April 18, 2016, the Defendant, FHP, expressly and/or impliedly permitted,
allowed, and/or authorized, the Defendant, MAYO, the use of the “Auto.”
18. On April 18, 2016, with the permission of the Defendant, FHP, Defendant,
Defendant, MAYO, headed northbound on State Road 7 (US 441) near the Old Hammock Way
Intersection in Royal Palm Beach, Palm Beach County, Florida, negligently operated and/or
maintained the “Auto” and collided with the vehicle in which Plaintiff was driving.
19. As aresult of said accident, the Plaintiff suffered permanent bodily injury, resulting
pain and suffering, disability, disfigurement, mental anguish, ioss of capacity for the enjoyment of
life, expense of hospitalization, medical and nursing care and treatment, an aggravation of a pre-
existing condition, lost wages and the loss of the ability to earn money in the future. The losses
are permanent and continuing. The Plaintiff shall suffer additional losses in the future.
WHEREFORE, Plaintiff demands judgment for damages against the Defendant, FHP, in
an amount in excess of the jurisdictional limits of this Court, together with his costs and for any
and all further relief this Court deems just and proper.
Page 3 of 7COUNT II
20. The Plaintiff adopts paragraphs | through 14 above by reference as though fully set
forth herein.
21. On or about April 18, 2016, Plaintiff was the driver of a 2006 GMC Envoy headed
northbound on State Road 7 (US 441) near the Old Hammock Way Intersection in Royal Palm Beach,
Palm Beach County, Florida.
22. At said time and place, Defendant, MAYO collided with the vehicle in which
Plaintiff was driving.
23. As a result, Plaintiff sustained permanent bodily injury, resulting pain and
suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life,
expense of hospitalization, medical and nursing care and treatment, an aggravation of a pre-
existing condition, loss of income, and loss of ability to earn income in the future. The losses are
permanent and continuing. The Plaintiff shall suffer additional losses in the future.
WHEREFORE, Plaintiff demands judgment for damages against the Defendant, MAYO
in an amount in excess of the jurisdictionai iimits of this Court, and for any and ail further reitef
this Court deems just and proper.
COUNT Il
PLAINTIFF, CLARK’S CLAIM FOR
NEGLIGENT ENTRUSTMENT AGAINST DEFENDANT, FHP
24. — The Plaintiff adopts by reference paragraphs | through 14 herein as though fully
set forth.
25. On April 18, 2016, Defendant, FHP allowed Defendant, MAYO to use the “Auto”.
26. On that date, Defendant, FHP knew, or had reason to know, that Defendant, MAYO
Page 4 of 7would use the Auto in a manner involving unreasonable risk of physical harm to himself and
others, including the Plaintiff, since:
a. On or about August 10, 1999, Defendant, MAYO was cited for careless driving, a
violation of Florida Statute § 316.1925;
b. Onor about July 25, 2002, Defendant, MAYO was cited for failure to use due care;
c. On or about September 22, 2002, Defendant, MAYO was cited for failure to use a
seat belt;
d. On or about January 31, 2003, Defendant, MAYO was cited for unlawful speed, a
violation of Florida Statute § 316.183;
e. On or about April 9, 2003, Defendant, MAYO was cited for unlawful speed, a
violation of Florida Statute § 316.183;
f. On or about July 1, 2003, Defendant, MAYO was cited for unlawful speed, a
violation of Florida Statute § 316.183;
g. On or about October 22, 2003, Defendant, MAYO was cited for unlawful speed, a
violation of Florida Statute § 316.183;
h. Gnor about June 3, 2004, Defendant, MAYO was cited for fatiure to obey a traffic
control device, a violation of Florida Statute § 316.074(1);
i. On or about June 15, 2004, Defendant, MAYO was cited for unlawful speed, a
violation of Florida Statute § 316.183;
j- On or about July 9, 2004, Defendant, MAYO was cited for unlawful speed, a
violation of Florida Statute § 316.183;
k. On or about April 28, 2005, Defendant, MAYO was cited for unlawful speed, a
arinlatinn af Blavida Gtatnte § 21K 122.
ViOlau0n OL d1Ollda OLatute y 510.100
Py
Page 5 of 71. Onor about September 14, 2005, Defendant, MAYO was cited for careless driving,
a violation of Florida Statute § 316.1925;
27. As a result of Defendant, FHP negligently entrusting the Auto to Defendant,
MAYO, the Plaintiff sustained permanent bodily injury, resulting pain and suffering, disability,
disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of
hospitalization, medical and nursing care and treatment, an aggravation of a pre-existing condition,
loss of income, and loss of ability to earn income in the future. The losses are permanent and
continuing. The Plaintiff shall suffer additional losses in the future.
WHEREFORE, the Plaintiff demands judgment for damages according to law against
Defendant, FHP, in an amount in excess of the jurisdictional limits of this Court, and for any and
all further relief this Court deems just and proper.
PLAINTIFF DEMANDS TRIAL BY JURY ON ALL ISSUES SO TRIABLE.
Dated: December 10, 2018
Respectfully submitted,
STEINBERG | LAW, P.A.
A ttnener fnew Dinien
Auomey 10r Paint
10 S.E. 1% Avenue, Ste. C.
Delray Beach, FL 33444
Telephone: (561) 630-0053
Facsimile: (561) 594-1838
E-Mail:_brett@pbrettsteinberglaw.com
steinberglawservice@gmail.com
By: /s/ Brett. Stetaterg
Brett M. Steinberg, Esquire
Florida Bar No.: 11677
Page 6 of 7STEINGER, ISCOE & GREENE, P.A.
ATTORNEYS AT Law
OFFICES RePLy To: WEST PaLM BEACH
September 26, 2016
West Palm Beach eee eat
1645 Palm Beach Lakes Blvd rioriaa Hignway Patrol
sthFloor ~~ 2900 Apalachee Pkwy
WetPum beech. 001 Tallahassee, FL 32399
(561)-616-5550
(561)-616-5551 fax
, Re: Our Client : Errol Inniss
taal Date of Incident : 4/18/2016
Port St Lacie, FL 34986. Our File No. > 162783
7a) 61 5334 |
(nysrsesatex | Dear Sir/Madam:
Fort Lauderdale 7 - 7 a Prey
2400ECommercialsd | Kindly be advised we represent Errol Inniss who sustained personal injuries as a
Ssitesoo | result of a motor vehicle crash as noted above.
Fort Lauderdale, FL 33308.
(954-491-7701 . x . ,
54491-7703 | ‘f you have insurance, please notify your insurance company immediately.
Fiotida Statute §627.4137, “Disciosure of certain information tequired” provides:
Miami
ene osc tine Each insurer which does or may provide liability insurance coverage to pay all or
fe
Con Gable, rt 33101 | @ POrtion of any claim which might be made shall provide, within 30 days of the
(30s).869.6000 | Written request of the claimant, a statement, under oath, of a corporate officer or
05)-s6e-6o1fx | the insurer's claims manager or Superintendent setting forth the following
information with regard to each known policy of insurance, including excess or
umbralla inctiransa:
MINION HOU GNICS.
(a) The name of the insurer.
(b) The name of each insured.
(c) The limits of the liability coverage.
fd\ A ctatamant af anu nal.
\S; A SAEKEMSN St aiiy POuGy G7 COVerage deiense which such insurer
reasonably believes is available to such insurer at the time of filing
such statement.
(e) Acopy of the policy.
In addition, the insured, or her or his insurance agent, upon written request of
the claimant or the ts attorney, shaw disciase the mame and coverage
of each known insu
fo the claimant and shail forward such request for
information as required by this subsection to all affected insurers. The insurer
INJURYLAWYERS.COM 1-800-INJURY-LAwshall then supply the information required in this subsection to the claimant
within 30 days of receipt of such request.
Fla. Stat. §627.4137(1). If you had no insurance at the time of the incident,
kindly contact us immediately. Otherwise, you should act promptly to protect
any and all rights that you may have.
You must also maintain any and all event data recorders, "black boxes,”
airbag deployment module, infotainment systems and other electronic
recording devices in the event that they are removed from your vehicle.
This request specifically includes any repairs done to your vehicle; so, be
certain that the repair shop does not destroy, dispose of or use as a core
return such evidence.
PLEASE GOVERN YOURSELF ACCORDINGLY.
Very truly yours,
STEINGER, ISCOE &
fy .
By:_/ fi hay Z 9x
Angire Cdza, FSquire
AGimicUNITED STATES
_ = POSTAL SERVICE,
Date Produced: 01/23/2017
STEINGER ISCOE & GREENE PA:
The following is the delivery information for Certified Mail™/RRE item number 9414 8149
0109 5041 2809 81. Our records indicate that this item was delivered on 01/17/2017 at
08:19 a.m. in TALLAHASSEE, FL 32314. The scanned image of the recipient information
is provided below.
Signature of Recipient: #e ——
nm nm ae
Ande Mea ateteua.
AUUIESS UF RECIPICIIL -
Thank you for selecting the Postal Service for your mailing needs. If you require
additional assistance, please contact your local post office or Postal Service
representative.
Sincerely,
United States Postal Service
The customer reference number shown below is not validated or endorsed by the United
States Postal Service. It is solely for customer use.
Customer Reference Number: 162783mlcUNITED STATES
B POSTAL SERVICE.
Date Produced: 01/23/2017
STEINGER ISCOE & GREENE PA:
The following is the delivery information for Certified Mail™/RRE item number 9414 8149
0109 5041 2809 98. Our records indicate that this item was delivered on 01/17/2017 at
08:19 a.m. in TALLAHASSEE, FL 32314. The scanned image of the recipient information
is provided below.
Signature of Recipient: | A =
ipient :
a
a
a
Sh
al
a
a
ui
Agar
poy:
Thank you for selecting the Postal Service for your mailing needs. If you require
additional assistance, please contact your local post office or Postal Service
representative.
Sincerely,
United States Postal Service
The customer reference number shown below is not validated or endorsed by the United
States Postal Service. It is solely for customer use.
Customer Reference Number: 162783 micUNITED STATES
B POSTAL SERVICE.
Date Produced: 01/23/2017
STEINGER ISCOE & GREENE PA:
The following is the delivery information for Certified Mail™/RRE item number 9414 8149
0109 5041 2810 01. Our records indicate that this item was delivered on 01/17/2017 at
07:33 a.m. in TALLAHASSEE, FL 32314. The scanned image of the recipient information
is provided below.
cop y owowow
Signature of Recipient :
AAdlenan af. ae
AUUIESDS Ul NGUIPICI . TT
Thank you for selecting the Postal Service for your mailing needs. If you require
additional assistance, please contact your local post office or Postal Service
representative.
Sincerely,
United States Postal Service
The customer reference number shown below is not validated or endorsed by the United
States Postal Service. It is solely for customer use.
Customer Reference Number: 162783 mic.UNITED STATES
Ba POSTAL SERVICE.
Date Produced: 01/23/2017
STEINGER ISCOE & GREENE PA:
The following is the delivery information for Certified Mail™/RRE item number 9414 8149
0109 5041 2810 18. Our records indicate that this item was delivered on 01/17/2017 at
07:33 a.m. in TALLAHASSEE, FL 32314. The scanned image of the recipient information
is provided below.
y eww
Address of Recipient: .,.-..-...
Thank you for selecting the Postal Service for your mailing needs. If you require
additional assistance, please contact your local post office or Postal Service
iepresentatve.
Sincerely,
United States Postal Service
The customer reference number shown below is not validated or endorsed by the United
States Postal Service. It is solely for customer use,
Customer Reference Number: 162783 mic
Preview
wes CASE NUMBER: 502018CA015498XXXXMB Division: AD **** Filing # 81880695 E-Filed 12/10/2018 02:40:07 PM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: Div.: ERROLL INNISS, vs. THE FLORIDA HIGHWAY PATROL, A division of FLORIDA DEPARTMENT OF HIGHWAY SAFETY & MOTOR VEHICLES, an Agency of the State of Florida, and TROOPER RICKY LEE MAYO, Defendants. / COMPLAINT COME(S) NOW, the Plaintiff, ERROLL INNISS (hereinafter “Plaintiff”), by and through the undersigned counsel and sue the Defendant(s), THE FLORIDA HIGHWAY PATROL, A division of FLORIDA DEPARTMENT OF HIGHWAY SAFETY & MOTOR VEHICLES, an Agency of the State of Florida (hereinafter “FHP”) and TROOPER RICKY LEE MAYO (hereinafter “MAYO”) and in support thereof states as follows: JURISDICTION & GENERAL ALLEGATIONS 1. That the instant action is for money damages in excess of Fifteen Thousand Dollars ($15,000.00) and meets the jurisdictional limits of this court. 2. That at all times material hereto, the Plaintiff was and is located in Palm Beach County, Florida. 3. At all times material hereto, FHP was and is located in Leon County, Florida and maintains offices in Paim Beach County, Fiorida. CHEN. DAIAARCACUAAIINTY Cl CUADAND ANAFY FLEDY 491N1INN1a N9-AN-N7 DAA PILL. PALE BLAU VUUINE TT, PL, OHI. DUUN, ULL, 1errureuiu ue.tu.ur ive4. That at all times material hereto, Defendant, MAYO, was and is a resident of Hillsborough County, Florida and is otherwise sui juris. 5. That at all times material hereto, all actions relevant hereto took place in Palm Beach County, Florida. 6. On or about April 18, 2016, Defendant, FHP owned a 2012 Dodge Charger bearing license plate number: FHP113 with VIN: 2C3CDXAT1CH226605 (hereinafter the “Auto”). 7. On or about April 18, 2016, Defendant, MAYO was employed by Defendant, FHP and was the driver of the Auto. 8. On or about April 18, 2016, Plaintiff was the driver of a 2006 GMC Envoy headed northbound on State Road 7 (US 441) near the Old Hammock Way Intersection in Royal Palm Beach, Palm Beach County, Florida. 9. At said time and place, Defendant, MAYO, also headed northbound on State Road 7 (US 441) near the Old Hammock Way Intersection in Royal Palm Beach, Palm Beach County, Florida, collided with the vehicle in which Plaintiff was driving. 10. Venue is proper in Palm Beach County because the acts and omissions referred to herein occurred in Palm Beach County, Fiorida and FHP maintains business offices in Paim Beach County, Florida. ll. On or about September 26, 2016, Plaintiff served written notice of the claim upon Defendant, FHP by certified mail, return receipt requested in accordance with §768.28, Fla. Stat. Defendant, FHP received this notice on January 17, 2017. A true and correct copy of the notice and return receipt is attached as Exhibit “A” and incorporated herein by reference. 12. Defendant, FHP has denied Plaintiff's claims. 12 Darvon. at tn 814999 Dlasida Gtatutac Dafandant ELID has wroived savaraian 19 ruisualt Wy 00.20, Pi0liGa Siauws, VeciGain, ri as Waiveu Sovereign Page 2 of 7immunity for this cause of action. 14. All conditions precedent to bringing this cause of action have occurred, or have been performed, excused, discharged, satisfied or waived. COUNTI PLAINTIFF’S CLAIM FOR NEGLIGENCE AGAINST DEFENDANT, FHP 15. Plaintiff adopts by reference paragraphs | through 14 above by reference as though fully set forth herein. 16. On April 18, 2016, the Defendant, FHP, owned the “Auto”. 17. On April 18, 2016, the Defendant, FHP, expressly and/or impliedly permitted, allowed, and/or authorized, the Defendant, MAYO, the use of the “Auto.” 18. On April 18, 2016, with the permission of the Defendant, FHP, Defendant, Defendant, MAYO, headed northbound on State Road 7 (US 441) near the Old Hammock Way Intersection in Royal Palm Beach, Palm Beach County, Florida, negligently operated and/or maintained the “Auto” and collided with the vehicle in which Plaintiff was driving. 19. As aresult of said accident, the Plaintiff suffered permanent bodily injury, resulting pain and suffering, disability, disfigurement, mental anguish, ioss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, an aggravation of a pre- existing condition, lost wages and the loss of the ability to earn money in the future. The losses are permanent and continuing. The Plaintiff shall suffer additional losses in the future. WHEREFORE, Plaintiff demands judgment for damages against the Defendant, FHP, in an amount in excess of the jurisdictional limits of this Court, together with his costs and for any and all further relief this Court deems just and proper. Page 3 of 7COUNT II 20. The Plaintiff adopts paragraphs | through 14 above by reference as though fully set forth herein. 21. On or about April 18, 2016, Plaintiff was the driver of a 2006 GMC Envoy headed northbound on State Road 7 (US 441) near the Old Hammock Way Intersection in Royal Palm Beach, Palm Beach County, Florida. 22. At said time and place, Defendant, MAYO collided with the vehicle in which Plaintiff was driving. 23. As a result, Plaintiff sustained permanent bodily injury, resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, an aggravation of a pre- existing condition, loss of income, and loss of ability to earn income in the future. The losses are permanent and continuing. The Plaintiff shall suffer additional losses in the future. WHEREFORE, Plaintiff demands judgment for damages against the Defendant, MAYO in an amount in excess of the jurisdictionai iimits of this Court, and for any and ail further reitef this Court deems just and proper. COUNT Il PLAINTIFF, CLARK’S CLAIM FOR NEGLIGENT ENTRUSTMENT AGAINST DEFENDANT, FHP 24. — The Plaintiff adopts by reference paragraphs | through 14 herein as though fully set forth. 25. On April 18, 2016, Defendant, FHP allowed Defendant, MAYO to use the “Auto”. 26. On that date, Defendant, FHP knew, or had reason to know, that Defendant, MAYO Page 4 of 7would use the Auto in a manner involving unreasonable risk of physical harm to himself and others, including the Plaintiff, since: a. On or about August 10, 1999, Defendant, MAYO was cited for careless driving, a violation of Florida Statute § 316.1925; b. Onor about July 25, 2002, Defendant, MAYO was cited for failure to use due care; c. On or about September 22, 2002, Defendant, MAYO was cited for failure to use a seat belt; d. On or about January 31, 2003, Defendant, MAYO was cited for unlawful speed, a violation of Florida Statute § 316.183; e. On or about April 9, 2003, Defendant, MAYO was cited for unlawful speed, a violation of Florida Statute § 316.183; f. On or about July 1, 2003, Defendant, MAYO was cited for unlawful speed, a violation of Florida Statute § 316.183; g. On or about October 22, 2003, Defendant, MAYO was cited for unlawful speed, a violation of Florida Statute § 316.183; h. Gnor about June 3, 2004, Defendant, MAYO was cited for fatiure to obey a traffic control device, a violation of Florida Statute § 316.074(1); i. On or about June 15, 2004, Defendant, MAYO was cited for unlawful speed, a violation of Florida Statute § 316.183; j- On or about July 9, 2004, Defendant, MAYO was cited for unlawful speed, a violation of Florida Statute § 316.183; k. On or about April 28, 2005, Defendant, MAYO was cited for unlawful speed, a arinlatinn af Blavida Gtatnte § 21K 122. ViOlau0n OL d1Ollda OLatute y 510.100 Py Page 5 of 71. Onor about September 14, 2005, Defendant, MAYO was cited for careless driving, a violation of Florida Statute § 316.1925; 27. As a result of Defendant, FHP negligently entrusting the Auto to Defendant, MAYO, the Plaintiff sustained permanent bodily injury, resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, an aggravation of a pre-existing condition, loss of income, and loss of ability to earn income in the future. The losses are permanent and continuing. The Plaintiff shall suffer additional losses in the future. WHEREFORE, the Plaintiff demands judgment for damages according to law against Defendant, FHP, in an amount in excess of the jurisdictional limits of this Court, and for any and all further relief this Court deems just and proper. PLAINTIFF DEMANDS TRIAL BY JURY ON ALL ISSUES SO TRIABLE. Dated: December 10, 2018 Respectfully submitted, STEINBERG | LAW, P.A. A ttnener fnew Dinien Auomey 10r Paint 10 S.E. 1% Avenue, Ste. C. Delray Beach, FL 33444 Telephone: (561) 630-0053 Facsimile: (561) 594-1838 E-Mail:_brett@pbrettsteinberglaw.com steinberglawservice@gmail.com By: /s/ Brett. Stetaterg Brett M. Steinberg, Esquire Florida Bar No.: 11677 Page 6 of 7STEINGER, ISCOE & GREENE, P.A. ATTORNEYS AT Law OFFICES RePLy To: WEST PaLM BEACH September 26, 2016 West Palm Beach eee eat 1645 Palm Beach Lakes Blvd rioriaa Hignway Patrol sthFloor ~~ 2900 Apalachee Pkwy WetPum beech. 001 Tallahassee, FL 32399 (561)-616-5550 (561)-616-5551 fax , Re: Our Client : Errol Inniss taal Date of Incident : 4/18/2016 Port St Lacie, FL 34986. Our File No. > 162783 7a) 61 5334 | (nysrsesatex | Dear Sir/Madam: Fort Lauderdale 7 - 7 a Prey 2400ECommercialsd | Kindly be advised we represent Errol Inniss who sustained personal injuries as a Ssitesoo | result of a motor vehicle crash as noted above. Fort Lauderdale, FL 33308. (954-491-7701 . x . , 54491-7703 | ‘f you have insurance, please notify your insurance company immediately. Fiotida Statute §627.4137, “Disciosure of certain information tequired” provides: Miami ene osc tine Each insurer which does or may provide liability insurance coverage to pay all or fe Con Gable, rt 33101 | @ POrtion of any claim which might be made shall provide, within 30 days of the (30s).869.6000 | Written request of the claimant, a statement, under oath, of a corporate officer or 05)-s6e-6o1fx | the insurer's claims manager or Superintendent setting forth the following information with regard to each known policy of insurance, including excess or umbralla inctiransa: MINION HOU GNICS. (a) The name of the insurer. (b) The name of each insured. (c) The limits of the liability coverage. fd\ A ctatamant af anu nal. \S; A SAEKEMSN St aiiy POuGy G7 COVerage deiense which such insurer reasonably believes is available to such insurer at the time of filing such statement. (e) Acopy of the policy. In addition, the insured, or her or his insurance agent, upon written request of the claimant or the ts attorney, shaw disciase the mame and coverage of each known insu fo the claimant and shail forward such request for information as required by this subsection to all affected insurers. The insurer INJURYLAWYERS.COM 1-800-INJURY-LAwshall then supply the information required in this subsection to the claimant within 30 days of receipt of such request. Fla. Stat. §627.4137(1). If you had no insurance at the time of the incident, kindly contact us immediately. Otherwise, you should act promptly to protect any and all rights that you may have. You must also maintain any and all event data recorders, "black boxes,” airbag deployment module, infotainment systems and other electronic recording devices in the event that they are removed from your vehicle. This request specifically includes any repairs done to your vehicle; so, be certain that the repair shop does not destroy, dispose of or use as a core return such evidence. PLEASE GOVERN YOURSELF ACCORDINGLY. Very truly yours, STEINGER, ISCOE & fy . By:_/ fi hay Z 9x Angire Cdza, FSquire AGimicUNITED STATES _ = POSTAL SERVICE, Date Produced: 01/23/2017 STEINGER ISCOE & GREENE PA: The following is the delivery information for Certified Mail™/RRE item number 9414 8149 0109 5041 2809 81. Our records indicate that this item was delivered on 01/17/2017 at 08:19 a.m. in TALLAHASSEE, FL 32314. The scanned image of the recipient information is provided below. Signature of Recipient: #e —— nm nm ae Ande Mea ateteua. AUUIESS UF RECIPICIIL - Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representative. Sincerely, United States Postal Service The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. Customer Reference Number: 162783mlcUNITED STATES B POSTAL SERVICE. Date Produced: 01/23/2017 STEINGER ISCOE & GREENE PA: The following is the delivery information for Certified Mail™/RRE item number 9414 8149 0109 5041 2809 98. Our records indicate that this item was delivered on 01/17/2017 at 08:19 a.m. in TALLAHASSEE, FL 32314. The scanned image of the recipient information is provided below. Signature of Recipient: | A = ipient : a a a Sh al a a ui Agar poy: Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representative. Sincerely, United States Postal Service The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. Customer Reference Number: 162783 micUNITED STATES B POSTAL SERVICE. Date Produced: 01/23/2017 STEINGER ISCOE & GREENE PA: The following is the delivery information for Certified Mail™/RRE item number 9414 8149 0109 5041 2810 01. Our records indicate that this item was delivered on 01/17/2017 at 07:33 a.m. in TALLAHASSEE, FL 32314. The scanned image of the recipient information is provided below. cop y owowow Signature of Recipient : AAdlenan af. ae AUUIESDS Ul NGUIPICI . TT Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representative. Sincerely, United States Postal Service The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. Customer Reference Number: 162783 mic.UNITED STATES Ba POSTAL SERVICE. Date Produced: 01/23/2017 STEINGER ISCOE & GREENE PA: The following is the delivery information for Certified Mail™/RRE item number 9414 8149 0109 5041 2810 18. Our records indicate that this item was delivered on 01/17/2017 at 07:33 a.m. in TALLAHASSEE, FL 32314. The scanned image of the recipient information is provided below. y eww Address of Recipient: .,.-..-... Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service iepresentatve. Sincerely, United States Postal Service The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use, Customer Reference Number: 162783 mic