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Filing # 169524471 E-Filed 03/23/2023 05:51:33 PM
IN THE CIRCUIT COURT OF THE 19" JUDICIAL CIRCUIT
IN AND FOR OKEECHOBEE COUNTY, FLORIDA
CASE NO.
EDNA JENKINS,
Plaintiff,
Vv.
WILLIAM S. CURREN,
CURREN ELECTRIC COMPANY,
and FALLON SUE CURREN,
Defendants.
/
COMPLAINT
Plaintiff, EDNA JENKINS, and sues Defendants, WILLIAM S. CURREN,
ELECTRIC COMPANY, and FALLON SUE CURREN, and alleges:
1 This is an action for damages that exceeds Fifty Thousand
Dollars ($50,000.00), exclusive of interest, costs and attorneys' fees.
2 All incidents giving rise to this cause of action occurred in Okeechobee
County, Florida.
3 Plaintiff, EDNA JENKINS, is a natural person residing in St. Lucie
County, Florida.
4 At all times material to this action, Defendant, CURREN ELECTRIC
COMPANY, was an active Florida corporation authorized to do and doing business at
3859 Highway 441 North, in Okeechobee County, Florida.
5 At all times material to this action, Defendant, FALLON SUE CURREN,
Electronically Filed Okeechobee Case # 2023000176CAAXMX 03/23/2023 05:51:33 PM
was aresident of Okeechobee, Okeechobee County, Florida.
6 At all times, WILLIAM S. CURREN was a resident of Okeechobee,
Okeechobee County, Florida.
7 At all times material hereto, Defendant, WILLIAM S. CURREN, was the
owner of a Catahoula breed dog named Madison, whose address was 3859 Highway 441
North, Okeechobee, Okeechobee County, Florida.
8 On or about May 4, 2022, Plaintiff, EDNA JENKINS, was delivering a
package to Defendant, FALLON SUE CURREN’S home at 5930 NE 144" Street,
Okeechobee, Okeechobee County, Florida when Defendant's three (3) dogs,
including Madison ran towards the Plaintiff. Madison bit the Plaintiff, causing her
to fall to the ground. At the time, the Plaintiff was lawfully on the property.
9 At all times pertinent to this Complaint, Defendant WILLIAM S.
CURREN was in possession or control of the dog.
10. At all times pertinent to this Complaint, Defendant FALLON SUE
CURREN was in possession or control of the dog.
11. At all times pertinent to this Complaint, Defendant CURREN
ELECTRIC was in possession or control of the dog.
12. Pursuant to Florida Statute Section 767.04, WILLIAM S. CURREN,
CURREN and ELECTRIC COMPANY, and FALLON SUE CURREN are strictly liable for all
damages and injuries caused by Madision’s attack on Edna Jenkins.
13. As the proximate result of the above described attact, Plaintiff Edna
Jenkins suffered severe and permanent bodily injury and resulting pain and suffering,
severe and perment disfigurement, mental anguish, and expense of hospitilization,
medical, therapeutic, and reconstructive care and treatment. These losses are permanent
and continuing and will be suffered in the future.
WHEREFORE, the Plaintiff, EDNA JENKINS, sues the Defendants, WILLIAM
S. CURREN, CURREN ELECTRIC COMPANY AND FALLON SUE CURREN for damages
and demands judgment in excess of Fifty Thousand Dollars (50,000.00), plus
interest and costs, and demands trial by jury of all issues so triable.
Respectfully Submitted: March 23, 2023.
JOSH JONES LAW, P.A.
geagee
Joshua R. Jones, Esquire
Florida Bar No. 97649
15715 South Dixie Highway, Suite 214
Miami, FL 33157
Telephone: (305) 239-4878
Facsimile: (305) 760-4192
Primary Email: pleadings@joshjoneslaw.com
Secondary Email: josh@joshjoneslaw.com
Attorneys for Plaintiff
Preview
Filing # 169524471 E-Filed 03/23/2023 05:51:33 PM IN THE CIRCUIT COURT OF THE 19" JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CASE NO. EDNA JENKINS, Plaintiff, Vv. WILLIAM S. CURREN, CURREN ELECTRIC COMPANY, and FALLON SUE CURREN, Defendants. / COMPLAINT Plaintiff, EDNA JENKINS, and sues Defendants, WILLIAM S. CURREN, ELECTRIC COMPANY, and FALLON SUE CURREN, and alleges: 1 This is an action for damages that exceeds Fifty Thousand Dollars ($50,000.00), exclusive of interest, costs and attorneys' fees. 2 All incidents giving rise to this cause of action occurred in Okeechobee County, Florida. 3 Plaintiff, EDNA JENKINS, is a natural person residing in St. Lucie County, Florida. 4 At all times material to this action, Defendant, CURREN ELECTRIC COMPANY, was an active Florida corporation authorized to do and doing business at 3859 Highway 441 North, in Okeechobee County, Florida. 5 At all times material to this action, Defendant, FALLON SUE CURREN, Electronically Filed Okeechobee Case # 2023000176CAAXMX 03/23/2023 05:51:33 PM was aresident of Okeechobee, Okeechobee County, Florida. 6 At all times, WILLIAM S. CURREN was a resident of Okeechobee, Okeechobee County, Florida. 7 At all times material hereto, Defendant, WILLIAM S. CURREN, was the owner of a Catahoula breed dog named Madison, whose address was 3859 Highway 441 North, Okeechobee, Okeechobee County, Florida. 8 On or about May 4, 2022, Plaintiff, EDNA JENKINS, was delivering a package to Defendant, FALLON SUE CURREN’S home at 5930 NE 144" Street, Okeechobee, Okeechobee County, Florida when Defendant's three (3) dogs, including Madison ran towards the Plaintiff. Madison bit the Plaintiff, causing her to fall to the ground. At the time, the Plaintiff was lawfully on the property. 9 At all times pertinent to this Complaint, Defendant WILLIAM S. CURREN was in possession or control of the dog. 10. At all times pertinent to this Complaint, Defendant FALLON SUE CURREN was in possession or control of the dog. 11. At all times pertinent to this Complaint, Defendant CURREN ELECTRIC was in possession or control of the dog. 12. Pursuant to Florida Statute Section 767.04, WILLIAM S. CURREN, CURREN and ELECTRIC COMPANY, and FALLON SUE CURREN are strictly liable for all damages and injuries caused by Madision’s attack on Edna Jenkins. 13. As the proximate result of the above described attact, Plaintiff Edna Jenkins suffered severe and permanent bodily injury and resulting pain and suffering, severe and perment disfigurement, mental anguish, and expense of hospitilization, medical, therapeutic, and reconstructive care and treatment. These losses are permanent and continuing and will be suffered in the future. WHEREFORE, the Plaintiff, EDNA JENKINS, sues the Defendants, WILLIAM S. CURREN, CURREN ELECTRIC COMPANY AND FALLON SUE CURREN for damages and demands judgment in excess of Fifty Thousand Dollars (50,000.00), plus interest and costs, and demands trial by jury of all issues so triable. Respectfully Submitted: March 23, 2023. JOSH JONES LAW, P.A. geagee Joshua R. Jones, Esquire Florida Bar No. 97649 15715 South Dixie Highway, Suite 214 Miami, FL 33157 Telephone: (305) 239-4878 Facsimile: (305) 760-4192 Primary Email: pleadings@joshjoneslaw.com Secondary Email: josh@joshjoneslaw.com Attorneys for Plaintiff