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IN THE CIRCUIT COURT OF NTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
RAYMOND CHARLES ROBERTS CASE NO 23000600CA
Plaintiff,
LISA ANNE STONE and
SOUTHERN OWNERS INSURANCE
COMPANY, a Foreign Profit Corporation
Defendant
COMPLAINT AND DEMAND FOR JURY TRIAL
COMES NOW, Plaintiff, RAYMOND CHARLES ROBERTS by and through h
undersigned counsel and files this action against Defendants, LISA ANNE STONE (hereinafter
and SOUTHERN OWNERS INSURANCE COMPANY, a Foreign Profit Corporation
(hereinafter “SOUTHERN OWNERS and alleges as follows:
This is an action for damages that exceeds the sum of FIFTY
DOLLARS ($ exclusive of costs, interest, and attorneys’ fees (The estimated value of
Plaintiffs claim is in excess of the minimum jurisdictional threshold required by this Court).
Accordingly, Plaintiff has entered “over ” in the civil cover sheet for the “amount of the
claim” as required in the preamble to the civil cover sheet for jurisdictional purposes only (The
Florida Supreme Court has ordered that the estimated “amount of claim” be set forth in the civil
cover sheet for data collection and clerical purposes only). The actual value of Plaintiff's claim
will be determined by a fair and just jury in accordance with Article 1, Section 21, Fla. Const.
At all times material hereto, Plaintiff, RAYMOND CHARLES ROBERTS, an
individual, is and was a resident of _arlotte County, FloridaAt all times material hereto, Defendant, LISA n individual is and
was aresident Charlotte County, Florida.
At all times material hereto, Defendant, SOUTHERN OWNERS INSURANCE
COMPANY is and was a Foreign Profit Corporation authorized to do business in the State of
Florida and was conducting business in the State of Florida
That or about May 27, 2020, Plaintiff was involved in a motor vehicle crash with
Defendant, at or near he intersection of Kings Hwy. and Harbor View Rd., in Port
Charlotte, Charlotte County, Florida wherein Defendant, operated h_ vehicle in a
careless, negligent, and reckless manner and collided with the vehicle that Plaintiff was operating
causing Plaintiff to sustain permanent and severe injuries
At the time of the May 27, 2020 motor vehicle crash in Port Charlotte, Charlotte
County, Florida Defendant, an underinsured motorist.
Atall times material to the allegations contained herein, Plaintiff was insured and/or
a beneficiary under a contract for automobile insurance issued by Defendant SOUTHERN
OWNERS, policy number , for uninsured/underinsured motorist coverage which
was in full force and effect o May 27, 2020
This Court has jurisdiction over this matter as the crash, injuries and subsequent
medical treatment occurred in whole, or in part, in Sarasota County, Florida.
COUNT I NEGLIGENCE OF DEFENDANT LISA ANNE STONE
Plaintiff re alleges and re affirms the allegations contained in Paragraphs One (_ through
Eight (above as if fully set forth herein and further allegesOn or about the morning May 27, 2020 Defendant the owner and
operator of a 2012 Hyundai motor vehicle _ or near the intersection of Kings Hwy. and Harbor
View Rd., in Port Charlotte, Charlotte County, Florida
On or about May 27, 2020 Plaintiff stopped at a red light on Kings Hwy in
Port Charlotte, Charlotte County, Florida Defendant, was also traveling behind Plaintiff
E. Venice Ave. on Kings Hwy. in Port Charlotte, Charlotte County, Florida Defendant
carelessly, negligently, and recklessly operated and maintained 2012 Hyundai motor vehicle
when he followed too closely and was unable to stop before colliding with the vehicle that
Plaintiff was operating causing Plaintiff to sustain permanent and severe injuries
As a direct and proximate result of the negligent conduct of Defendant
Plaintiff has suffered in the past and will continue to suffer in the future bodily injury and 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, loss of earnings, loss of
ability to earn money, permanent disfigurement and scarring. The losses are either permanent or
continuing and Plaintiff will suffer the losses in the future
WHEREFORE, Plaintiff, RAYMOND CHARLES ROBERTS demands judgment against
Defendant, LISA ANNE STONE, for damages in excess of $ plus costs in this action as
well as any other relief so entitled under Florida Law.
COUNT I UNDERINSURED MOTORIST CLAIM AGAINST SOUTHERN OWNERS
INSURANCE COMPANY
Plaintiff re alleges and re affirms the allegations contained in Paragraphs One (1) through
Eight (8) above as if fully set forth herein and further alleges:
At all times material hereto, Plaintiff, RAYMOND CHARLES ROBERTS
insured and/or a beneficiary under an automobile policy issued by Defendant, SOUTHERNOWNERS that includes and provides uninsured/underinsured motorist coverage, policy number
This action is brought pursuant to Section 627.727, Fla. Stat., against Defendant,
SOUTHERN OWNERS as the underinsured motorist insurer for Plaintiff, RAYMOND
CHARLES ROBERTS
That on or about May 27, 2020, Plaintiff, RAYMOND CHARLES ROBERTS, was
insured and/or a beneficiary under a contract of automobile insurance issued by Defendant,
SOUTHERN OWNERS, a Foreign Profit Corporation, policy number for
uninsured/underinsured motorist coverage which was in full force and effect on May 27, 2020
Alternatively, Defendant SOUTHERN OWNERS is responsible for underinsured motorists’
benefits pursuant to Section 627.727, Fla. Stat.
That on or about May 27, 2020, Plaintiff, RAYMOND CHARLES ROBERTS, was
seriously and permanently injured in an automobile accident caused by an underinsured motorist,
LISA ANNE STONE
As a direct and proximate result of the negligent conduct of Defendant
Plaintiff has suffered in the past and will continue to suffer in the future bodily injury and 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, loss of earnings, loss of
ability to earn money, permanent disfigurement and scarring. The losses are either permanent or
continuing and Plaintiff will suffer the losses in the future
Plaintiff has requested underinsured motorist benefits pursuant to the benefits of
the contract of insurance with SOUTHERN OWNERS
Defendant, SOUTHERN OWNERS, has denied those benefits.Plaintiff, RAYMOND CHARLES ROBERTS, has complied with all conditions
precedent to entitlement of benefits under the above referenced policy.
WHEREFORE, Plaintiff, RAYMOND CHARLES ROBERTS, demands judgment against
Defendant, SOUTHERN OWNERS INSURANCE COMPANY, for damages in excess of
000.00 plus costs of this action and any other relief so entitled under Florida law.
DEMAND FOR JURY TRIAL
Plaintiff hereby demands a trial by jury on all issues so triable as a matter of right.
/s/ Jesse L. Podor
Jesse L. Podor
Attorney for Plaintiff
Florida Bar Number: 124474
THE PODOR LAW FIRM, LLC
1023 Manatee Avenue West
Suite 506
Bradenton Florida 34205
P: (941)
F: (941)
jpodor@podorlaw.com
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IN THE CIRCUIT COURT OF NTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION RAYMOND CHARLES ROBERTS CASE NO 23000600CA Plaintiff, LISA ANNE STONE and SOUTHERN OWNERS INSURANCE COMPANY, a Foreign Profit Corporation Defendant COMPLAINT AND DEMAND FOR JURY TRIAL COMES NOW, Plaintiff, RAYMOND CHARLES ROBERTS by and through h undersigned counsel and files this action against Defendants, LISA ANNE STONE (hereinafter and SOUTHERN OWNERS INSURANCE COMPANY, a Foreign Profit Corporation (hereinafter “SOUTHERN OWNERS and alleges as follows: This is an action for damages that exceeds the sum of FIFTY DOLLARS ($ exclusive of costs, interest, and attorneys’ fees (The estimated value of Plaintiffs claim is in excess of the minimum jurisdictional threshold required by this Court). Accordingly, Plaintiff has entered “over ” in the civil cover sheet for the “amount of the claim” as required in the preamble to the civil cover sheet for jurisdictional purposes only (The Florida Supreme Court has ordered that the estimated “amount of claim” be set forth in the civil cover sheet for data collection and clerical purposes only). The actual value of Plaintiff's claim will be determined by a fair and just jury in accordance with Article 1, Section 21, Fla. Const. At all times material hereto, Plaintiff, RAYMOND CHARLES ROBERTS, an individual, is and was a resident of _arlotte County, FloridaAt all times material hereto, Defendant, LISA n individual is and was aresident Charlotte County, Florida. At all times material hereto, Defendant, SOUTHERN OWNERS INSURANCE COMPANY is and was a Foreign Profit Corporation authorized to do business in the State of Florida and was conducting business in the State of Florida That or about May 27, 2020, Plaintiff was involved in a motor vehicle crash with Defendant, at or near he intersection of Kings Hwy. and Harbor View Rd., in Port Charlotte, Charlotte County, Florida wherein Defendant, operated h_ vehicle in a careless, negligent, and reckless manner and collided with the vehicle that Plaintiff was operating causing Plaintiff to sustain permanent and severe injuries At the time of the May 27, 2020 motor vehicle crash in Port Charlotte, Charlotte County, Florida Defendant, an underinsured motorist. Atall times material to the allegations contained herein, Plaintiff was insured and/or a beneficiary under a contract for automobile insurance issued by Defendant SOUTHERN OWNERS, policy number , for uninsured/underinsured motorist coverage which was in full force and effect o May 27, 2020 This Court has jurisdiction over this matter as the crash, injuries and subsequent medical treatment occurred in whole, or in part, in Sarasota County, Florida. COUNT I NEGLIGENCE OF DEFENDANT LISA ANNE STONE Plaintiff re alleges and re affirms the allegations contained in Paragraphs One (_ through Eight (above as if fully set forth herein and further allegesOn or about the morning May 27, 2020 Defendant the owner and operator of a 2012 Hyundai motor vehicle _ or near the intersection of Kings Hwy. and Harbor View Rd., in Port Charlotte, Charlotte County, Florida On or about May 27, 2020 Plaintiff stopped at a red light on Kings Hwy in Port Charlotte, Charlotte County, Florida Defendant, was also traveling behind Plaintiff E. Venice Ave. on Kings Hwy. in Port Charlotte, Charlotte County, Florida Defendant carelessly, negligently, and recklessly operated and maintained 2012 Hyundai motor vehicle when he followed too closely and was unable to stop before colliding with the vehicle that Plaintiff was operating causing Plaintiff to sustain permanent and severe injuries As a direct and proximate result of the negligent conduct of Defendant Plaintiff has suffered in the past and will continue to suffer in the future bodily injury and 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, loss of earnings, loss of ability to earn money, permanent disfigurement and scarring. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future WHEREFORE, Plaintiff, RAYMOND CHARLES ROBERTS demands judgment against Defendant, LISA ANNE STONE, for damages in excess of $ plus costs in this action as well as any other relief so entitled under Florida Law. COUNT I UNDERINSURED MOTORIST CLAIM AGAINST SOUTHERN OWNERS INSURANCE COMPANY Plaintiff re alleges and re affirms the allegations contained in Paragraphs One (1) through Eight (8) above as if fully set forth herein and further alleges: At all times material hereto, Plaintiff, RAYMOND CHARLES ROBERTS insured and/or a beneficiary under an automobile policy issued by Defendant, SOUTHERNOWNERS that includes and provides uninsured/underinsured motorist coverage, policy number This action is brought pursuant to Section 627.727, Fla. Stat., against Defendant, SOUTHERN OWNERS as the underinsured motorist insurer for Plaintiff, RAYMOND CHARLES ROBERTS That on or about May 27, 2020, Plaintiff, RAYMOND CHARLES ROBERTS, was insured and/or a beneficiary under a contract of automobile insurance issued by Defendant, SOUTHERN OWNERS, a Foreign Profit Corporation, policy number for uninsured/underinsured motorist coverage which was in full force and effect on May 27, 2020 Alternatively, Defendant SOUTHERN OWNERS is responsible for underinsured motorists’ benefits pursuant to Section 627.727, Fla. Stat. That on or about May 27, 2020, Plaintiff, RAYMOND CHARLES ROBERTS, was seriously and permanently injured in an automobile accident caused by an underinsured motorist, LISA ANNE STONE As a direct and proximate result of the negligent conduct of Defendant Plaintiff has suffered in the past and will continue to suffer in the future bodily injury and 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, loss of earnings, loss of ability to earn money, permanent disfigurement and scarring. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future Plaintiff has requested underinsured motorist benefits pursuant to the benefits of the contract of insurance with SOUTHERN OWNERS Defendant, SOUTHERN OWNERS, has denied those benefits.Plaintiff, RAYMOND CHARLES ROBERTS, has complied with all conditions precedent to entitlement of benefits under the above referenced policy. WHEREFORE, Plaintiff, RAYMOND CHARLES ROBERTS, demands judgment against Defendant, SOUTHERN OWNERS INSURANCE COMPANY, for damages in excess of 000.00 plus costs of this action and any other relief so entitled under Florida law. DEMAND FOR JURY TRIAL Plaintiff hereby demands a trial by jury on all issues so triable as a matter of right. /s/ Jesse L. Podor Jesse L. Podor Attorney for Plaintiff Florida Bar Number: 124474 THE PODOR LAW FIRM, LLC 1023 Manatee Avenue West Suite 506 Bradenton Florida 34205 P: (941) F: (941) jpodor@podorlaw.com