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16-2023-CA-007663-XXXX-MA Div: CV-C
Filing # 169523753 E-Filed 03/23/2023 05:41:53 PM
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA.
CASE NO.:
DIVISION:
DIONNE ORR,
Plaintiff,
vs.
TRAE MATTHEW STAKER and
DECLAN HAMMERLING,
Defendant.
-------------------------------------)
COMPLAINT
Plaintiff, DIONNE ORR, sues the Defendant, TRAE MATTHEW STAKER and
DECLAN HAMMERLING, and alleges:
1. This is an action for damages in excess of FIFTY THOUSAND AND NO/100
DOLLARS ($50,000.00), exclusive of attorneys’ fees, interest and costs, and Plaintiff(s) hereby
demand a trial by jury; accordingly, although, to file this Complaint, undersigned counsel is being
required by Order of the Supreme Court of Florida to contemporaneously complete a civil cover
sheet with a dollar figure as an estimated amount of claim for data collection and clerical processing
purposes only, the full monetary value of the damages suffered by Plaintiff (s) is yet to be determined
and will be decided in a verdict by the jury that judges the facts of this action in compliance with
Article II, Section 32, Florida Constitution.
2. At all times material hereto, Plaintiff DIONNE ORR was and is a resident of
Jacksonville, Duval County, Florida.
3. At all times material hereto, Defendant, TRAE MATTHER STAKER,was and is a
resident of Jacksonville, Duval County, Florida or, in the alternative, is not available to local service
of process.
4. At all times material hereto, Defendant, DECLAN HAMMERLING, was and is a
resident of Jacksonville, Duval County, Florida or, in the alternative, is not available to local service
of process.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 03/30/2023 04:51:19 PM
5. On or about September 14, 2022, the Defendant, TRAE MATTHEW STAKER,
owned a motor vehicle that was operated with his consent by Defendant, DECLAN
HAMMERLING, on Beach Boulevard in Jacksonville, Duval County, Florida.
6. At that time and place the Defendant, DECLAN HAMMERLING, negligently
operated or maintained the motor vehicle so that was involved in a motor vehicle collision that
included the Plaintiff’s motor vehicle.
7. As a result, Plaintiff, DIONNE ORR, suffered 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, and aggravation of a previously existing condition; said injury or disease consists in
whole or in part of a permanent injury within a reasonable degree of medical probability other than
scarring or disfigurement. The losses are either permanent or continuing and Plaintiff will suffer the
losses in the future. Plaintiff’s personal property and chattels were damaged and as a result Plaintiff
suffered loss of use.
WHEREFORE, Plaintiff DIONNE ORR demands judgment for damages against the
Defendants, TRAE MATTHEW STAKE and DECLAN HAMMERLING, and for such other
relief deemed proper by the Court. Plaintiff also demands a jury trial on all issues so triable.
DESIGNATION OF EMAIL ADDRESSES FOR E-SERVICE
COMES NOW, Donald Ray Coleman III, Esq., attorney for the Plaintiff, pursuant to
Fla.R.Civ.P. 2.516(b)(1)(A), and hereby designates the following email addresses for e-service in
this matter:
PRIMARY ADDRESS: RAY.III@RAYCOLEMANLAW.COM
SECONDARY ADDRESS: PLEADINGS@RAYCOLEMANLAW.COM
DESIGNATION OF EMAIL ADDRESSES FOR E-SERVICE
COMES NOW, Daniel Austin Coleman, Esq., attorney for the Plaintiff, pursuant to
Fla.R.Civ.P. 2.516(b)(1)(A), and hereby designates the following email addresses for e-service in
this matter:
PRIMARY ADDRESS: DANIEL@RAYCOLEMANLAW.COM
SECONDARY ADDRESS: PLEADINGS@RAYCOLEMANLAW.COM
DESIGNATION OF EMAIL ADDRESSES FOR E-SERVICE
COMES NOW, Donald Ray Coleman, Jr., Esq., attorney for the Plaintiff, pursuant to
Fla.R.Civ.P. 2.516(b)(1)(A), and hereby designates the following email addresses for e-service in
this matter:
PRIMARY ADDRESS: PLEADINGS@RAYCOLEMANLAW.COM
SECONDARY ADDRESS: KELLY@RAYCOLEMANLAW.COM
Law office of:
DONALD RAY COLEMAN, JR., P.A.
Date: March 23, 2023
/s/Donald Ray Coleman, Jr.
DONALD RAY COLEMAN, JR., ESQUIRE
Florida Bar No.: 357367
DONALD RAY COLEMAN III, ESQUIRE
Florida Bar No.: 114205
DANIEL AUSTIN COLEMAN, ESQUIRE
Florida Bar No.: 124962
Attorneys for Plaintiff
400 East Duval Street, Jacksonville, FL 32202
Phone: (904) 355-0548 Fax (904) 355-0402
Pleading service email:
Primary: pleadings@raycolemanlaw.com
Primary: ray.iii@raycolemanlaw.com
Primary: daniel@raycolemanlaw.com
Secondary: kelly@raycolemanlaw.com
Preview
16-2023-CA-007663-XXXX-MA Div: CV-C Filing # 169523753 E-Filed 03/23/2023 05:41:53 PM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA. CASE NO.: DIVISION: DIONNE ORR, Plaintiff, vs. TRAE MATTHEW STAKER and DECLAN HAMMERLING, Defendant. -------------------------------------) COMPLAINT Plaintiff, DIONNE ORR, sues the Defendant, TRAE MATTHEW STAKER and DECLAN HAMMERLING, and alleges: 1. This is an action for damages in excess of FIFTY THOUSAND AND NO/100 DOLLARS ($50,000.00), exclusive of attorneys’ fees, interest and costs, and Plaintiff(s) hereby demand a trial by jury; accordingly, although, to file this Complaint, undersigned counsel is being required by Order of the Supreme Court of Florida to contemporaneously complete a civil cover sheet with a dollar figure as an estimated amount of claim for data collection and clerical processing purposes only, the full monetary value of the damages suffered by Plaintiff (s) is yet to be determined and will be decided in a verdict by the jury that judges the facts of this action in compliance with Article II, Section 32, Florida Constitution. 2. At all times material hereto, Plaintiff DIONNE ORR was and is a resident of Jacksonville, Duval County, Florida. 3. At all times material hereto, Defendant, TRAE MATTHER STAKER,was and is a resident of Jacksonville, Duval County, Florida or, in the alternative, is not available to local service of process. 4. At all times material hereto, Defendant, DECLAN HAMMERLING, was and is a resident of Jacksonville, Duval County, Florida or, in the alternative, is not available to local service of process. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 03/30/2023 04:51:19 PM 5. On or about September 14, 2022, the Defendant, TRAE MATTHEW STAKER, owned a motor vehicle that was operated with his consent by Defendant, DECLAN HAMMERLING, on Beach Boulevard in Jacksonville, Duval County, Florida. 6. At that time and place the Defendant, DECLAN HAMMERLING, negligently operated or maintained the motor vehicle so that was involved in a motor vehicle collision that included the Plaintiff’s motor vehicle. 7. As a result, Plaintiff, DIONNE ORR, suffered 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, and aggravation of a previously existing condition; said injury or disease consists in whole or in part of a permanent injury within a reasonable degree of medical probability other than scarring or disfigurement. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. Plaintiff’s personal property and chattels were damaged and as a result Plaintiff suffered loss of use. WHEREFORE, Plaintiff DIONNE ORR demands judgment for damages against the Defendants, TRAE MATTHEW STAKE and DECLAN HAMMERLING, and for such other relief deemed proper by the Court. Plaintiff also demands a jury trial on all issues so triable. DESIGNATION OF EMAIL ADDRESSES FOR E-SERVICE COMES NOW, Donald Ray Coleman III, Esq., attorney for the Plaintiff, pursuant to Fla.R.Civ.P. 2.516(b)(1)(A), and hereby designates the following email addresses for e-service in this matter: PRIMARY ADDRESS: RAY.III@RAYCOLEMANLAW.COM SECONDARY ADDRESS: PLEADINGS@RAYCOLEMANLAW.COM DESIGNATION OF EMAIL ADDRESSES FOR E-SERVICE COMES NOW, Daniel Austin Coleman, Esq., attorney for the Plaintiff, pursuant to Fla.R.Civ.P. 2.516(b)(1)(A), and hereby designates the following email addresses for e-service in this matter: PRIMARY ADDRESS: DANIEL@RAYCOLEMANLAW.COM SECONDARY ADDRESS: PLEADINGS@RAYCOLEMANLAW.COM DESIGNATION OF EMAIL ADDRESSES FOR E-SERVICE COMES NOW, Donald Ray Coleman, Jr., Esq., attorney for the Plaintiff, pursuant to Fla.R.Civ.P. 2.516(b)(1)(A), and hereby designates the following email addresses for e-service in this matter: PRIMARY ADDRESS: PLEADINGS@RAYCOLEMANLAW.COM SECONDARY ADDRESS: KELLY@RAYCOLEMANLAW.COM Law office of: DONALD RAY COLEMAN, JR., P.A. Date: March 23, 2023 /s/Donald Ray Coleman, Jr. DONALD RAY COLEMAN, JR., ESQUIRE Florida Bar No.: 357367 DONALD RAY COLEMAN III, ESQUIRE Florida Bar No.: 114205 DANIEL AUSTIN COLEMAN, ESQUIRE Florida Bar No.: 124962 Attorneys for Plaintiff 400 East Duval Street, Jacksonville, FL 32202 Phone: (904) 355-0548 Fax (904) 355-0402 Pleading service email: Primary: pleadings@raycolemanlaw.com Primary: ray.iii@raycolemanlaw.com Primary: daniel@raycolemanlaw.com Secondary: kelly@raycolemanlaw.com