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Filing # 193345510 E-Filed 03/05/2024 02:09:36 PM
IN THE CIRCUIT COURT OF
THE THIRD JUDICIAL CIRCUIT
IN AND FOR MADISON COUNTY, FLORIDA
JAMES PRIDGEON,
Plaintiff, CASE NUMBER:
DIVISION:
vs.
HAGGAI VARDI, KATIE CARBAUGH,
and MICHAEL MERGENDAHL,
Defendants.
/
COMPLAINT
COMES NOW the Plaintiff, JAMES PRIDGEON, by and through his undersigned
attorneys, and sues the Defendants, HAGGAI VARDI, KATIE CARBAUGH, and MICHAEL
MERGENDAHL, 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.
2. On or about May 2, 2023, Defendants, HAGGAI VARDI and KATIE CARBAUGH,
owned a motor vehicle that was operated with consent by Defendant, MICHAEL MERGENDAHL,
at or near NE Dogwood Street, Madison, Madison County, Florida.
3. At that time and place defendants negligently operated or maintained the motor vehicle so
that it collided with Plaintiff.
4. Asa result, plaintiff suffered bodily injury and resulting pain and suffering, disability,
disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of
hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn
Electronically Filed Madison Case # 2024000025CAAXMX 03/05/2024 02:09:36 PM
money, and aggravation of a previously existing condition. The losses are either permanent or
continuing and plaintiffs will suffer the losses in the future.
WHEREFORE, plaintiff, JAMES PRIDGEON, demands judgment for damages against
defendants, HAGGAI VARDI, KATIE CARBAUGH, and MICHAEL MERGENDAHL, and other
such relief deemed proper by the Court. Plaintiff also demands a jury trial on all issues so triable.
Respectfully submitted this 5 day of March 2024.
MORGAN & MORGAN, PLLC
/s/ Jeremy R. Kriesel
JEREMY R. KRIESEL, ESQUIRE
Florida Bar Number: 90544
104 N. Main Street, Ste. 500
Gainesville, Florida 32601
Telephone: (352) 565-6528
Facsimile: (352) 565-6548
E-Service: jeremy. kriese|@forthepeople.com
shealy@forthepeople.com
Attorneys for Plaintiff
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Filing # 193345510 E-Filed 03/05/2024 02:09:36 PM IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT IN AND FOR MADISON COUNTY, FLORIDA JAMES PRIDGEON, Plaintiff, CASE NUMBER: DIVISION: vs. HAGGAI VARDI, KATIE CARBAUGH, and MICHAEL MERGENDAHL, Defendants. / COMPLAINT COMES NOW the Plaintiff, JAMES PRIDGEON, by and through his undersigned attorneys, and sues the Defendants, HAGGAI VARDI, KATIE CARBAUGH, and MICHAEL MERGENDAHL, 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. 2. On or about May 2, 2023, Defendants, HAGGAI VARDI and KATIE CARBAUGH, owned a motor vehicle that was operated with consent by Defendant, MICHAEL MERGENDAHL, at or near NE Dogwood Street, Madison, Madison County, Florida. 3. At that time and place defendants negligently operated or maintained the motor vehicle so that it collided with Plaintiff. 4. Asa result, plaintiff suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn Electronically Filed Madison Case # 2024000025CAAXMX 03/05/2024 02:09:36 PM money, and aggravation of a previously existing condition. The losses are either permanent or continuing and plaintiffs will suffer the losses in the future. WHEREFORE, plaintiff, JAMES PRIDGEON, demands judgment for damages against defendants, HAGGAI VARDI, KATIE CARBAUGH, and MICHAEL MERGENDAHL, and other such relief deemed proper by the Court. Plaintiff also demands a jury trial on all issues so triable. Respectfully submitted this 5 day of March 2024. MORGAN & MORGAN, PLLC /s/ Jeremy R. Kriesel JEREMY R. KRIESEL, ESQUIRE Florida Bar Number: 90544 104 N. Main Street, Ste. 500 Gainesville, Florida 32601 Telephone: (352) 565-6528 Facsimile: (352) 565-6548 E-Service: jeremy. kriese|@forthepeople.com shealy@forthepeople.com Attorneys for Plaintiff