Complaint,Petition: Bradshaw, Susan vs Rodriguez, Daniel Miguel

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                                Filing # 191084223 E-Filed 02/01/2024 06:26:32 PM


                    IN THE CIRCUIT COURT FOR THE THIRTEENTH JUDICIAL CIRCUIT
                             IN AND FOR HILLSBOROUGH COUNTY FLORIDA
                                           CIVIL DIVISION

             SUSAN BRADSHAW and
             STEWART BRADSHAW

                            Plaintiffs,
                                                                   CASE NO.: _________________
             vs.
                                                                   DIVISION: _________________
             DANIEL MIGUEL RODRIGUEZ,
             and CORY JOE CAULEY

                         Defendants.
             _______________________________/

                                                      COMPLAINT

                    COMES NOW, Plaintiffs, SUSAN BRADSHAW and STEWART BRADSHAW, by and

             through the undersigned attorney, and sue the Defendants, DANIEL MIGUEL RODRIGUEZ

             and CORY JOE CAULEY, and allege as follows:

                    1.      This is an action for damages which exceed $50,000.00, exclusive of costs, interest

             and attorney fees.

                    2.      At all material times herein, the Plaintiffs, SUSAN BRADSHAW and STEWART

             BRADSHAW, were residents of Hillsborough County, Florida.

                    3.      At all times material herein, the Defendant, DANIEL MIGUEL RODRIGUEZ,

             was a resident of Hillsborough County, Florida.

                    4.      At all times material herein, the Defendant, CORY JOE CAULEY, was a resident

             of Hillsborough County, Florida.

                    5.      On or about February 2, 2020, the Defendant, CORY JOE CAULEY, operated a

             motor vehicle with the consent and permission of the vehicle’s owner, the Defendant, DANIEL




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             MIGUEL RODRIGUEZ, at or near Fritzke Road and Doc Thompson Road in Hillsborough

             County, Florida.

                    6.      At that time and place, Defendant, CORY JOE CAULEY, driving south on Fritzke

             Road negligently operated the motor vehicle, causing it veer into the northbound lane and collide

             with the motor vehicle being driven north on Fritzke Road by Plaintiff, SUSAN BRADSHAW,

             which also carried Plaintiff, STEWART BRADSHAW as a passenger, forcing Plaintiffs’ vehicle

             off the road and causing it to collide with TECO power poles.

                    7.      As a result of the negligence of the Defendant, the Plaintiffs, SUSAN

             BRADSHAW and STEWART BRADSHAW, suffered bodily injury and resulting pain and

             suffering, disability, disfigurement, mental anguish, loss of the capacity for the enjoyment of life,

             expenses of hospitalization, medical and nursing care treatment, loss of earnings, loss of the ability

             to earn money and aggravation of a previously existing condition. These injuries are permanent

             in nature, and they will suffer damages in the future.

                    8.      Defendants, DANIEL MIGUEL RODRIGUEZ and CORY JOE CAULEY,

             damaged Plaintiff, SUSAN BRADSHAW’s, motor vehicle, and she lost use of it.

                    9.      Plaintiffs, SUSAN BRADSHAW and STEWART BRADSHAW, have complied

             with all conditions precedent before bringing this action.

                    WHEREFORE, Plaintiffs, SUSAN BRADSHAW and STEWART BRADSHAW,

             demand judgment for damages against Defendants, DANIEL MIGUEL RODRIGUEZ and

             CORY JOE CAULEY, in excess of the minimal jurisdictional limits of this Court, as well as

             post-judgment interest and the costs of bringing this action as allowed by law, and any other relief

             this Honorable Court deems just and proper.




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                                          DEMAND FOR JURY TRIAL

                     Plaintiffs, SUSAN BRADSHAW and STEWART BRADSHAW, demand a trial by jury

             of all issues so triable.

                                                             Respectfully submitted,



                                                             /s/ Timothy M. Dandar
                                                             TIMOTHY M. DANDAR, ESQ.
                                                             FBN: 86750
                                                             Post Office Box 55444
                                                             St. Petersburg, FL 33702
                                                             813-289-3858/Fax: 813-287-0895
                                                             TDandarLaw@gmail.com
                                                             TMD@DandarLaw.net
                                                             Attorney for Plaintiffs




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