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Filing #67937787 E-Filed 02/14/2018 10:04:18 AM
IN THE CIRCUIT COURT OF HILLSBOROUGH COUNTY, FLORIDA
GEICO GENERAL INSURANCE COMPANY
a/s/o ROXI JOHANSMEYER,
Plaintiff,
v CASE NO.
GREGORY POE, JR.,
Defendant.
/
PROPERTY DAMAGE AND UNINSURED MOTORIST
SUBROGATION COMPLAINT
Plaintiff, GEICO GENERAL INSURANCE COMPANY a/s/o ROXI
JOHANSMEYER, sues Defendant, GREGORY POE, JR., and alleges as follows:
1 This is an action for damages which exceeds $15,000.00.
2 Plaintiff, GEICO GENERAL INSURANCE COMPANY, is a
corporation authorized to transact business in the State of Florida.
3 At all times material to this Complaint, ROXI JOHANSMEYER
was insured by Plaintiff, GEICO GENERAL INSURANCE COMPANY, under a
policy of insurance providing, among other coverages, collision,
uninsured and underinsured motorist coverage.
4 On or about November 10, 2015, Defendant, GREGORY POE, JR.,
owned and operated a motor vehicle on Martin Luther King, or.
Boulevard (State Road 574) at or near its intersection with Taylor
Road near Seffner, Hillsborough County, Florida.
5 At that time and place, Defendant, GREGORY POE, OR., so
negligently and carelessly operated and/or maintained his motor
vehicle
vehicle 50 as to
to cause
cause it to
to collide
collide with
with aa motor
motor vehicle
vehicle owned
owned and
and
operated by ROXI JOHANSMEYER.
6 As a direct and proximate result of the Defendant's
negligence, ROXI JOHANSMEYER was injured in and about her body and
extremities, experienced pain and suffering, lost wages and suffered a
loss of earning capacity and incurred and will continue to incur
medical expenses; all of these injuries and damages are permanent and
continuing in nature and she will continue to suffer these losses in
the future.
2/14/2018 10:04 AM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 1
7 As a result of the injuries and damages sustained by its
insured, GEICO GENERAL INSURANCE COMPANY has paid a total of
$40,000.00 in uninsured/underinsured motorist benefits to, and on
behalf of, its insured, ROXI JOHANSMEYER.
8 As a further direct and proximate result of this accident,
Plaintiff was required to pay for the damages of the vehicle of its
insured, which included a $500.00 deductible paid directly by its
insureds and rental expense incurred while the damaged vehicle was
being repaired.
9 Plaintiff is entitled to prejudgment interest on all
liquidated damages from the date of payment to its insureds.
WHEREFORE, Plaintiff demands judgment against the Defendant in
the amount of $44,154.76 in damages, plus prejudgment interest and the
costs of bringing this action.
Gary SV Rabin, Esquire
GrayRobinson, P.A.
Post Office Box 3
Lakeland, Florida 33802
(863) 284-2232
Florida Bar No. 261051
Attorneys for Plaintiff
4070600.2599
2/14/2018 10:04 AM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 2
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Filing #67937787 E-Filed 02/14/2018 10:04:18 AM IN THE CIRCUIT COURT OF HILLSBOROUGH COUNTY, FLORIDA GEICO GENERAL INSURANCE COMPANY a/s/o ROXI JOHANSMEYER, Plaintiff, v CASE NO. GREGORY POE, JR., Defendant. / PROPERTY DAMAGE AND UNINSURED MOTORIST SUBROGATION COMPLAINT Plaintiff, GEICO GENERAL INSURANCE COMPANY a/s/o ROXI JOHANSMEYER, sues Defendant, GREGORY POE, JR., and alleges as follows: 1 This is an action for damages which exceeds $15,000.00. 2 Plaintiff, GEICO GENERAL INSURANCE COMPANY, is a corporation authorized to transact business in the State of Florida. 3 At all times material to this Complaint, ROXI JOHANSMEYER was insured by Plaintiff, GEICO GENERAL INSURANCE COMPANY, under a policy of insurance providing, among other coverages, collision, uninsured and underinsured motorist coverage. 4 On or about November 10, 2015, Defendant, GREGORY POE, JR., owned and operated a motor vehicle on Martin Luther King, or. Boulevard (State Road 574) at or near its intersection with Taylor Road near Seffner, Hillsborough County, Florida. 5 At that time and place, Defendant, GREGORY POE, OR., so negligently and carelessly operated and/or maintained his motor vehicle vehicle 50 as to to cause cause it to to collide collide with with aa motor motor vehicle vehicle owned owned and and operated by ROXI JOHANSMEYER. 6 As a direct and proximate result of the Defendant's negligence, ROXI JOHANSMEYER was injured in and about her body and extremities, experienced pain and suffering, lost wages and suffered a loss of earning capacity and incurred and will continue to incur medical expenses; all of these injuries and damages are permanent and continuing in nature and she will continue to suffer these losses in the future. 2/14/2018 10:04 AM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 1 7 As a result of the injuries and damages sustained by its insured, GEICO GENERAL INSURANCE COMPANY has paid a total of $40,000.00 in uninsured/underinsured motorist benefits to, and on behalf of, its insured, ROXI JOHANSMEYER. 8 As a further direct and proximate result of this accident, Plaintiff was required to pay for the damages of the vehicle of its insured, which included a $500.00 deductible paid directly by its insureds and rental expense incurred while the damaged vehicle was being repaired. 9 Plaintiff is entitled to prejudgment interest on all liquidated damages from the date of payment to its insureds. WHEREFORE, Plaintiff demands judgment against the Defendant in the amount of $44,154.76 in damages, plus prejudgment interest and the costs of bringing this action. Gary SV Rabin, Esquire GrayRobinson, P.A. Post Office Box 3 Lakeland, Florida 33802 (863) 284-2232 Florida Bar No. 261051 Attorneys for Plaintiff 4070600.2599 2/14/2018 10:04 AM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 2