On July 07, 2022 a
Complaint,Petition
was filed
involving a dispute between
Geico General Insurance Company,
Geico Indemnity Company,
and
Dora L Lopez Cruiz,
for AUTO NEGLIGENCE CASE Division: CV-B
in the District Court of Duval County.
Preview
16-2022-CA-003897-XXXX-MA Div: CV-B
Filing # 152853733 E-Filed 07/07/2022 11:39:21 AM
IN THE CIRCUIT COURT FOR THE
4TH JUDICIAL CIRCUIT IN AND FOR
DUVAL COUNTY, FLORIDA
GEICO GENERAL INSURANCE COMPANY
as subrogee of ALEJANDRO ROSARIO JR.
and RADHA CHENNU and GEICO INDEMNITY
COMPANY as subrogee of THOMAS FREY,
Plaintiffs, CASE NO.:
-vs-
DORA LUZ LOPEZ CRUIZ,
Defendant.
nanny
COMPLAINT.
Plaintiffs, GEICO GENERAL INSURANCE COMPANY as subrogee of ALEJANDRO ROSARIO
JR. and RADHA CHENNU and GEICO INDEMNITY COMPANY as subrogee of THOMAS FREY sue
Defendant, DORA LUZ LOPEZ CRUIZ, for $41,303.78 as Damages, and would allege:
1 This is an action for damages greater than $30,000.00.
2 At all times material hereto, ALEJANDRO ROSARIO JR., RADHA CHENNU, and
THOMAS FREY were insured by Plaintiff corporations duly licensed to transact the business
of insurance in and about the State of Florida.
Defendant is a resident of the State of Florida, or alternatively, Defendant is concealing
themselves within the State of Florida or is a non-resident of the State of Florida who
accepted the privilege extended by Florida law to nonresidents of operating a motor vehicle
and by operation of the motor vehicle in person thereby constituted the Secretary of State of
Florida as the Defendant's agent for the service of process in a civil action in Florida arising
out of or by reason of any accident or collision occurring within Florida in which the motor
vehicle is involved according to Florida Statute ss 48.171.
On or about June 26, 2021, Defendant owned and operated a motor vehicle in such a
negligent and careless manner that a collision occurred in DUVAL County, Florida causing
property damage to the Plaintiffs’ insureds' respective vehicles.
Defendant owed ALEJANDRO ROSARIO JR., RADHA CHENNU, and THOMAS FREY a
duty of care while operating the motor vehicle.
Defendant breached said duty of care by causing the subject motor vehicle accident.
At said time and place, there were policies of insurance issued by Plaintiffs which covered the
aforementioned damages.
Pursuant to said policies of insurance, Plaintiffs paid to or on behalf of their respective
insureds the total sum of $41,303.78 in property damage related expenses and Plaintiff is
entitled to subrogation.
9. Defendant owes Plaintiffs the total sum of $41,303.78
10. All conditions precedent to this action have occurred, been met or been waived.
WHEREFORE, Plaintiffs demand Judgment against Defendant, DORA LUZ LOPEZ CRUIZ, for
$41,303.78 in damages, plus interest and costs.
LAW OFFICE OF YATES & SCHILLER, P.A.
7900 Glades Road, Suite 405
Boca Raton, Florida 33434
Designated email address for pleadings only:
pleadings@yatesandschiller.com
Phone: 561-477-7729
Fax: 561-477-7731
By: s/_ Bruce H. Schiller, Esq.
BRUCE H. SCHILLER, Esq.
YS40017 FBN: 982725
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 07/07/2022 02:05:29 PM
Document Filed Date
July 07, 2022
Case Filing Date
July 07, 2022
Category
AUTO NEGLIGENCE CASE Division: CV-B
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16-2022-CA-003897-XXXX-MA Div: CV-B Filing # 152853733 E-Filed 07/07/2022 11:39:21 AM IN THE CIRCUIT COURT FOR THE 4TH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA GEICO GENERAL INSURANCE COMPANY as subrogee of ALEJANDRO ROSARIO JR. and RADHA CHENNU and GEICO INDEMNITY COMPANY as subrogee of THOMAS FREY, Plaintiffs, CASE NO.: -vs- DORA LUZ LOPEZ CRUIZ, Defendant. nanny COMPLAINT. Plaintiffs, GEICO GENERAL INSURANCE COMPANY as subrogee of ALEJANDRO ROSARIO JR. and RADHA CHENNU and GEICO INDEMNITY COMPANY as subrogee of THOMAS FREY sue Defendant, DORA LUZ LOPEZ CRUIZ, for $41,303.78 as Damages, and would allege: 1 This is an action for damages greater than $30,000.00. 2 At all times material hereto, ALEJANDRO ROSARIO JR., RADHA CHENNU, and THOMAS FREY were insured by Plaintiff corporations duly licensed to transact the business of insurance in and about the State of Florida. Defendant is a resident of the State of Florida, or alternatively, Defendant is concealing themselves within the State of Florida or is a non-resident of the State of Florida who accepted the privilege extended by Florida law to nonresidents of operating a motor vehicle and by operation of the motor vehicle in person thereby constituted the Secretary of State of Florida as the Defendant's agent for the service of process in a civil action in Florida arising out of or by reason of any accident or collision occurring within Florida in which the motor vehicle is involved according to Florida Statute ss 48.171. On or about June 26, 2021, Defendant owned and operated a motor vehicle in such a negligent and careless manner that a collision occurred in DUVAL County, Florida causing property damage to the Plaintiffs’ insureds' respective vehicles. Defendant owed ALEJANDRO ROSARIO JR., RADHA CHENNU, and THOMAS FREY a duty of care while operating the motor vehicle. Defendant breached said duty of care by causing the subject motor vehicle accident. At said time and place, there were policies of insurance issued by Plaintiffs which covered the aforementioned damages. Pursuant to said policies of insurance, Plaintiffs paid to or on behalf of their respective insureds the total sum of $41,303.78 in property damage related expenses and Plaintiff is entitled to subrogation. 9. Defendant owes Plaintiffs the total sum of $41,303.78 10. All conditions precedent to this action have occurred, been met or been waived. WHEREFORE, Plaintiffs demand Judgment against Defendant, DORA LUZ LOPEZ CRUIZ, for $41,303.78 in damages, plus interest and costs. LAW OFFICE OF YATES & SCHILLER, P.A. 7900 Glades Road, Suite 405 Boca Raton, Florida 33434 Designated email address for pleadings only: pleadings@yatesandschiller.com Phone: 561-477-7729 Fax: 561-477-7731 By: s/_ Bruce H. Schiller, Esq. BRUCE H. SCHILLER, Esq. YS40017 FBN: 982725 ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 07/07/2022 02:05:29 PM