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Filing # 169302302 E-Filed 03/21/2023 07:44:02 PM
IN THE CIRCUIT COURT OF THE 2ND JUDICIAL CIRCUIT
IN AND FOR WAKULLA FLORIDA
CIVIL DIVISION
CASE NO:
HANNAH TAYLOR,
Plaintiff,
vs.
JULIE ANN SCOTT, and USAA
INSURANCE COMPANY,
Defendants.
/
COMPLAINT
Plaintiff, HANNAH TAYLOR, files this complaint against Defendants, JULIE ANN
SCOTT, and USAA Insurance Company, and alleges:
1 This is an action for damages that exceeds the sum of FIFTY THOUSAND
DOLLARS ($50,000.00), exclusive of costs, interest and attorneys’ fees (The estimated value of
Plaintiff's claim is in excess of the minimum jurisdictional threshold required by this Court).
Accordingly, Plaintiff, HANNAH TAYLOR, has entered “$50,001” in the civil cover sheet for the
“estimated 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, HANNAH TAYLOR’S claim will be determined by a fair and just jury in accordance with
Article 1, Section 21, Fla. Const.
2. The 2ND Judicial Circuit Court has venue pursuant to Florida Statutes, §47.011
because the cause of action occurred in Wakulla County, Florida.
Electronically Filed Wakulla Case # 23000316CAAXMX 03/21/2023 07:44:02 PM
1 6
THE PARTIES
3 At all times material to this action, Plaintiff, HANNAH TAYLOR, was a natural
person residing in Wakulla County, Florida.
4 At all times material to this action, Defendant, JULIE ANN SCOTT was a natural
person residing in Wakulla County, Florida.
5 At all times material to this action, Defendant, USAA Insurance Company, is an
insurance corporation which is and was authorized and doing business in Wakulla County, Florida.
FACTS
6. On or about 01/18/2023, Plaintiff, HANNAH TAYLOR, was operating a motor
vehicle in Wakulla County, Florida.
7 At that time and place, Defendant, JULIE ANN SCOTT, was the owner and/or
operator of a motor vehicle in Wakulla County, Florida.
8 At that time and place, Defendant, JULIE ANN SCOTT, negligently operated and/or
maintained the motor vehicle such that it caused a crash involving Plaintiff, HANNAH TAYLOR.
COUNTI
CLAIM OF HANNAH TAYLOR AGAINST JULIE ANN SCOTT
Plaintiff, HANNAH TAYLOR, reiterates and realleges Paragraphs 1 through 8 as if more
fully set forth herein and further alleges:
9 Defendant, JULIE ANN SCOTT, owed Plaintiff, HANNAH TAYLOR, the duty to
operate the motor vehicle he or she was driving in a safe, careful and prudent manner so as not to
collide with the vehicle containing Plaintiff, HANNAH TAYLOR.
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10. Defendant, JULIE ANN SCOTT, breached that duty by carelessly and negligently
operating his or her motor vehicle in such a manner that it caused a crash involving Plaintiff,
HANNAH TAYLOR.
11. As a direct and proximate result of the negligence of Defendant, JULIE ANN
SCOTT, Plaintiff, HANNAH TAYLOR, suffered bodily injury including a permanent injury to
the body as a whole, pain and suffering of both a physical and mental nature, disability, physical
impairment, disfigurement, mental anguish, inconvenience, loss of capacity for the enjoyment of
life, aggravation of an existing condition, expense of hospitalization, medical and nursing care and
treatment, loss of earnings, loss of ability to earn money and loss of ability to lead and enjoy a
normal life. The losses are either permanent or continuing and Plaintiff will suffer the losses in the
future. Plaintiff, HANNAH TAYLOR also suffered other damages, including, but not limited to,
loss of the use of the subject vehicle, damage to the subject vehicle. Plaintiff, HANNAH
TAYLOR, will suffer or incur the injuries, expenses and impairment in the future.
WHEREFORE, the Plaintiff, HANNAH TAYLOR, demands judgment against the
Defendant, JULIE ANN SCOTT, in an amount in excess of Fifty Thousand ($50,000) Dollars and
requests a trial by jury of all issues triable as of right by a jury.
COUNT IT
CLAIM OF HANNAH TAYLOR AGAINST USAA INSURANCE COMPANY.
Plaintiff, HANNAH TAYLOR, reiterates and realleges Paragraphs 1 through 11 as if
more fully set forth herein and further alleges:
12. At all times material hereto Plaintiff, HANNAH TAYLOR, had in force and effect a
policy of insurance providing uninsured/underinsured motorists’ coverage with Defendant, USAA
Insurance Company.
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13. Defendant, USAA Insurance Company, has in its custody and control a copy of the
insurance policy and, therefore, it is not attached to the Complaint.
14. This action is brought pursuant to Section 627.727, Fla. Stat., against Defendant,
USAA Insurance Company, as the uninsured/underinsured motorist insurer for Plaintiff, HANNAH
TAYLOR.
15. Defendant, USAA Insurance Company, is responsible for uninsured/underinsured
motorists’ benefits as provided in the contract of insurance. Alternatively, Defendant, USAA
Insurance Company, is responsible for uninsured/underinsured motorists’ benefits pursuant to Section
627.727, Fla. Stat.
16. That at all times material hereto the Defendant, JULIE ANN SCOTT was
uninsured/underinsured for the motor vehicle accident that occurred in this case.
17. Plaintiff, HANNAH TAYLOR has furnished Defendant, USAA Insurance Company,
timely notice of the automobile accident and proof of the claim for damages described above and has
otherwise performed all conditions precedent to entitle recovery under the uninsured/underinsured
portion of the policy but Defendant, USAA Insurance Company, has denied that coverage exists
and/or refused to pay Plaintiff, HANNAH TAYLOR the full value of the claim.
18. As a direct and proximate result of the negligence of Defendant, JULIE ANN SCOTT,
Plaintiff, HANNAH TAYLOR suffered bodily injury including a permanent injury to the body as a
whole, pain and suffering of both a physical and mental nature, disability, physical impairment,
disfigurement, mental anguish, inconvenience, loss of capacity for the enjoyment of life, aggravation
of an existing condition, expense of hospitalization, medical and nursing care and treatment, loss of
earnings, loss of ability to earn money and loss of ability to lead and enjoy a normal life. The losses
are either permanent or continuing and Plaintiff, HANNAH TAYLOR will suffer the losses in the
13916966
future. Plaintiff, HANNAH TAYLOR, will suffer or incur the injuries, expenses, and impairment in
the future.
WHEREFORE, the Plaintiff, HANNAH TAYLOR, demands judgment against the
Defendant, USAA Insurance Company, in an amount in excess of Fifty Thousand ($50,000) Dollars,
and requests a trial by jury of all issues triable as of right by a jury.
RESPECTFULLY submitted this 21% day of March 2023.
s/ Martin Jaffe
Martin Jaffe, Esq.
Florida Bar No.: 144258
Morgan & Morgan
20 N Orange Ave, Suite 1600
Orlando, FL 32801
P: (407) 420-1414
F: (407) 425-8171
mjaffe@forthepeople.com
Attorney for Plaintiff
13916966
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Filing # 169302302 E-Filed 03/21/2023 07:44:02 PM IN THE CIRCUIT COURT OF THE 2ND JUDICIAL CIRCUIT IN AND FOR WAKULLA FLORIDA CIVIL DIVISION CASE NO: HANNAH TAYLOR, Plaintiff, vs. JULIE ANN SCOTT, and USAA INSURANCE COMPANY, Defendants. / COMPLAINT Plaintiff, HANNAH TAYLOR, files this complaint against Defendants, JULIE ANN SCOTT, and USAA Insurance Company, and alleges: 1 This is an action for damages that exceeds the sum of FIFTY THOUSAND DOLLARS ($50,000.00), exclusive of costs, interest and attorneys’ fees (The estimated value of Plaintiff's claim is in excess of the minimum jurisdictional threshold required by this Court). Accordingly, Plaintiff, HANNAH TAYLOR, has entered “$50,001” in the civil cover sheet for the “estimated 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, HANNAH TAYLOR’S claim will be determined by a fair and just jury in accordance with Article 1, Section 21, Fla. Const. 2. The 2ND Judicial Circuit Court has venue pursuant to Florida Statutes, §47.011 because the cause of action occurred in Wakulla County, Florida. Electronically Filed Wakulla Case # 23000316CAAXMX 03/21/2023 07:44:02 PM 1 6 THE PARTIES 3 At all times material to this action, Plaintiff, HANNAH TAYLOR, was a natural person residing in Wakulla County, Florida. 4 At all times material to this action, Defendant, JULIE ANN SCOTT was a natural person residing in Wakulla County, Florida. 5 At all times material to this action, Defendant, USAA Insurance Company, is an insurance corporation which is and was authorized and doing business in Wakulla County, Florida. FACTS 6. On or about 01/18/2023, Plaintiff, HANNAH TAYLOR, was operating a motor vehicle in Wakulla County, Florida. 7 At that time and place, Defendant, JULIE ANN SCOTT, was the owner and/or operator of a motor vehicle in Wakulla County, Florida. 8 At that time and place, Defendant, JULIE ANN SCOTT, negligently operated and/or maintained the motor vehicle such that it caused a crash involving Plaintiff, HANNAH TAYLOR. COUNTI CLAIM OF HANNAH TAYLOR AGAINST JULIE ANN SCOTT Plaintiff, HANNAH TAYLOR, reiterates and realleges Paragraphs 1 through 8 as if more fully set forth herein and further alleges: 9 Defendant, JULIE ANN SCOTT, owed Plaintiff, HANNAH TAYLOR, the duty to operate the motor vehicle he or she was driving in a safe, careful and prudent manner so as not to collide with the vehicle containing Plaintiff, HANNAH TAYLOR. 13916966 10. Defendant, JULIE ANN SCOTT, breached that duty by carelessly and negligently operating his or her motor vehicle in such a manner that it caused a crash involving Plaintiff, HANNAH TAYLOR. 11. As a direct and proximate result of the negligence of Defendant, JULIE ANN SCOTT, Plaintiff, HANNAH TAYLOR, suffered bodily injury including a permanent injury to the body as a whole, pain and suffering of both a physical and mental nature, disability, physical impairment, disfigurement, mental anguish, inconvenience, loss of capacity for the enjoyment of life, aggravation of an existing condition, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money and loss of ability to lead and enjoy a normal life. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. Plaintiff, HANNAH TAYLOR also suffered other damages, including, but not limited to, loss of the use of the subject vehicle, damage to the subject vehicle. Plaintiff, HANNAH TAYLOR, will suffer or incur the injuries, expenses and impairment in the future. WHEREFORE, the Plaintiff, HANNAH TAYLOR, demands judgment against the Defendant, JULIE ANN SCOTT, in an amount in excess of Fifty Thousand ($50,000) Dollars and requests a trial by jury of all issues triable as of right by a jury. COUNT IT CLAIM OF HANNAH TAYLOR AGAINST USAA INSURANCE COMPANY. Plaintiff, HANNAH TAYLOR, reiterates and realleges Paragraphs 1 through 11 as if more fully set forth herein and further alleges: 12. At all times material hereto Plaintiff, HANNAH TAYLOR, had in force and effect a policy of insurance providing uninsured/underinsured motorists’ coverage with Defendant, USAA Insurance Company. 13916966 13. Defendant, USAA Insurance Company, has in its custody and control a copy of the insurance policy and, therefore, it is not attached to the Complaint. 14. This action is brought pursuant to Section 627.727, Fla. Stat., against Defendant, USAA Insurance Company, as the uninsured/underinsured motorist insurer for Plaintiff, HANNAH TAYLOR. 15. Defendant, USAA Insurance Company, is responsible for uninsured/underinsured motorists’ benefits as provided in the contract of insurance. Alternatively, Defendant, USAA Insurance Company, is responsible for uninsured/underinsured motorists’ benefits pursuant to Section 627.727, Fla. Stat. 16. That at all times material hereto the Defendant, JULIE ANN SCOTT was uninsured/underinsured for the motor vehicle accident that occurred in this case. 17. Plaintiff, HANNAH TAYLOR has furnished Defendant, USAA Insurance Company, timely notice of the automobile accident and proof of the claim for damages described above and has otherwise performed all conditions precedent to entitle recovery under the uninsured/underinsured portion of the policy but Defendant, USAA Insurance Company, has denied that coverage exists and/or refused to pay Plaintiff, HANNAH TAYLOR the full value of the claim. 18. As a direct and proximate result of the negligence of Defendant, JULIE ANN SCOTT, Plaintiff, HANNAH TAYLOR suffered bodily injury including a permanent injury to the body as a whole, pain and suffering of both a physical and mental nature, disability, physical impairment, disfigurement, mental anguish, inconvenience, loss of capacity for the enjoyment of life, aggravation of an existing condition, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money and loss of ability to lead and enjoy a normal life. The losses are either permanent or continuing and Plaintiff, HANNAH TAYLOR will suffer the losses in the 13916966 future. Plaintiff, HANNAH TAYLOR, will suffer or incur the injuries, expenses, and impairment in the future. WHEREFORE, the Plaintiff, HANNAH TAYLOR, demands judgment against the Defendant, USAA Insurance Company, in an amount in excess of Fifty Thousand ($50,000) Dollars, and requests a trial by jury of all issues triable as of right by a jury. RESPECTFULLY submitted this 21% day of March 2023. s/ Martin Jaffe Martin Jaffe, Esq. Florida Bar No.: 144258 Morgan & Morgan 20 N Orange Ave, Suite 1600 Orlando, FL 32801 P: (407) 420-1414 F: (407) 425-8171 mjaffe@forthepeople.com Attorney for Plaintiff 13916966