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Filing # 112659268 E-Filed 08/3 1/2020 04:41:07 PM
IN THE CIRCUIT COURT OF THE EIGHTEENTH
JUDICIAL CIRCUIT IN AND FOR BREVARD
COUNTY FLORIDA
CASE NO:
JAHNEE HOLMES,
Plaintiff,
vs.
JOSHUA HOWARD,
Defendant.
/
COMPLAINT
Plaintiff, JAHNEE HOLMES, sues Defendant, JOSHUA HOWARD, and alleges:
1 This is an action for damages that exceeds the sum of THIRTY THOUSAND
DOLLARS ($30,000.00), 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 has entered “$30,001” 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's
claim will be determined by a fair and just jury in accordance with Article 1, Section 21, Fla.
Const.
2. At all times material to this action, Plaintiff was a natural person residing in Brevard
County, Florida.
Filing 112659268 VS 05-2020-CA-040792-XXXX-XX
3 At all times material to this action, Defendant was a natural person residing in
Brevard County, Florida.
4 On or about January 10, 2020, Plaintiff was operating a motor vehicle traveling
southbound on US-1 in Brevard County, Florida.
5 At that time and place, Defendant owned and operated a motor vehicle traveling
southbound on US-1 in Brevard County, Florida.
6. At that time and place, Defendant negligently operated and/or maintained the motor
vehicle so that it collided with Plaintiff's motor vehicle.
7 As a direct and proximate result of Defendant's negligence, Plaintiff 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. Plaintiffs motor vehicle was also
damaged.
WHEREFORE, Plaintiff, JAHNEE HOLMES, demands judgment for damages against
Defendant, JOSHUA HOWARD, and other such relief deemed proper by the Court. Plaintiff also
demands a jury trial on all issues so triable.
RESPECTFULLY submitted this 31st day of August, 2020
Zs/ Ryan McCarville
Ryan McCarville, Esq.
FBN: 0117831
Filing 112659268 VS 05-2020-CA-040792-XXXX-XX
Morgan & Morgan, P.A.
940 S Harbor City Blvd
Melbourne, FL 32901
Telephone: (321) 327-6263
Facsimile: (321) 327-6897
Primary email: rmecarville@forthepeople.com
Secondary email:
mbhutchinsonwilkins@forthepeople.com
Attorney for Plaintiff
Filing 112659268 VS 05-2020-CA-040792-XXXX-XX
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Filing # 112659268 E-Filed 08/3 1/2020 04:41:07 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY FLORIDA CASE NO: JAHNEE HOLMES, Plaintiff, vs. JOSHUA HOWARD, Defendant. / COMPLAINT Plaintiff, JAHNEE HOLMES, sues Defendant, JOSHUA HOWARD, and alleges: 1 This is an action for damages that exceeds the sum of THIRTY THOUSAND DOLLARS ($30,000.00), 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 has entered “$30,001” 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's claim will be determined by a fair and just jury in accordance with Article 1, Section 21, Fla. Const. 2. At all times material to this action, Plaintiff was a natural person residing in Brevard County, Florida. Filing 112659268 VS 05-2020-CA-040792-XXXX-XX 3 At all times material to this action, Defendant was a natural person residing in Brevard County, Florida. 4 On or about January 10, 2020, Plaintiff was operating a motor vehicle traveling southbound on US-1 in Brevard County, Florida. 5 At that time and place, Defendant owned and operated a motor vehicle traveling southbound on US-1 in Brevard County, Florida. 6. At that time and place, Defendant negligently operated and/or maintained the motor vehicle so that it collided with Plaintiff's motor vehicle. 7 As a direct and proximate result of Defendant's negligence, Plaintiff 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. Plaintiffs motor vehicle was also damaged. WHEREFORE, Plaintiff, JAHNEE HOLMES, demands judgment for damages against Defendant, JOSHUA HOWARD, and other such relief deemed proper by the Court. Plaintiff also demands a jury trial on all issues so triable. RESPECTFULLY submitted this 31st day of August, 2020 Zs/ Ryan McCarville Ryan McCarville, Esq. FBN: 0117831 Filing 112659268 VS 05-2020-CA-040792-XXXX-XX Morgan & Morgan, P.A. 940 S Harbor City Blvd Melbourne, FL 32901 Telephone: (321) 327-6263 Facsimile: (321) 327-6897 Primary email: rmecarville@forthepeople.com Secondary email: mbhutchinsonwilkins@forthepeople.com Attorney for Plaintiff Filing 112659268 VS 05-2020-CA-040792-XXXX-XX