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Filing # 194600184 E-Filed 03/22/2024 10:25:56 AM
IN THE CIRCUIT COURT OF THE 18TH
JUDICIAL CIRCUIT, IN AND FOR
BREVARD COUNTY, FLORIDA
MARSHALL WEBB CASE NO:
Plaintiff(s),
Vs.
CHRISTOPHER CLUCKEY,
Defendant.
COMPLAINT
COMES NOW the Plaintiff, MARSHALL WEBB, by and through the undersigned
counsel and hereby sue the Defendant, CHRISTOPHER CLUCKEY, and say:
1 This is an action for damages which exceeds the jurisdictional requirements of this
Court.
This Court has jurisdiction over the parties and subject matter of this action in that:
(a) Plaintiff, MARSHALL WEBB, is a natural person and resident of Florida
residing in Melbourne, Brevard County, Florida.
(b) Defendant CHRISTOPHER CLUCKEY is a natural person and resident of
Florida residing in Rockledge, Brevard County, Florida;
(c) Venue is proper because the incident giving rise to the instant action occurred
in Brevard County, Florida.
FACTS COMMON TO ALL COUNTS
3 On or about September 8, 2023, defendant CHRISTOPHER CLUCKEY was
operating a motor vehicle at or near Fiske Road in Rockledge, Brevard County, Florida.
4 Defendant CHRISTOPHER CLUCKEY was the owner of the vehicle he was
operating at the above-described time and place.
1
Filing 194600184 VS 05-2024-CA-021340-XXCA-BC
5 At the time and place described above, defendant CHRISTOPHER CLUCKEY
negligently operated and maintained his motor vehicle so that it collided with a vehicle driven by
Plaintiff, MARSHALL WEBB, causing significant injuries.
COUNTI
NEGLIGENCE OF CHRISTOPHER CLUCKEY
Plaintiff realleges and incorporates herein by reference each and every factual allegation
as contained in Paragraphs 1 through 6 as if fully set forth herein.
7 Defendant, CHRISTOPHER CLUCKEY, negligently operated or maintained his
2010 Mazda vehicle causing it to impact the vehicle driven by Plaintiff, MARSHALL WEBB.
8 As a direct and proximate result of the negligence of the defendant
CHRISTOPHER CLUCKEY, Plaintiff MARSHALL WEBB suffered significant bodily injury
and resulting pain and suffering, impairment, disability, disfigurement, mental anguish, loss of
capacity for the enjoyment of life, expenses of hospitalization, medical and nursing care and
treatment, loss of earnings, aggravation and/or activation of a pre-existing condition or defect, and
loss of ability to earn money. The injuries to the Plaintiff are permanent and he will continue to
suffer the losses in the future.
WHEREFORE, Plaintiff MARSHALL WEBB demands judgment for damages against
defendant, CHRISTOPHER CLUCKEY, including costs of this action, and further demands a trial
by jury on all issues so triable, and for such other relief as this Court deems just and proper.
Filing 194600184 VS 05-2024-CA-021340-XXCA-BC
DEMAND FOR JURY TRIAL
Plaintiff, MARSHALL WEBB, demands a jury trial on all issues so triable of each and
every one of the Counts set forth above.
RESPECTFULLY submitted this DATED this 22nd day of March 2024.
/s/ Michael Ghaly, ESQUIRE
Michael Ghaly, Esq.
Florida Bar No.: 122385
Dan Newlin Injury Attorneys
7335 W. Sand Lake Road, Suite 300
Orlando, FL 32819
Phone: 407-203-6565
Fax: 407-203-6565
Attorneys for Plaintiff
PRINCIPAL EMAIL ADDRESS:
Michael.Ghaly@newlinlaw.com
Filing 194600184 VS 05-2024-CA-021340-XXCA-BC
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Filing # 194600184 E-Filed 03/22/2024 10:25:56 AM IN THE CIRCUIT COURT OF THE 18TH JUDICIAL CIRCUIT, IN AND FOR BREVARD COUNTY, FLORIDA MARSHALL WEBB CASE NO: Plaintiff(s), Vs. CHRISTOPHER CLUCKEY, Defendant. COMPLAINT COMES NOW the Plaintiff, MARSHALL WEBB, by and through the undersigned counsel and hereby sue the Defendant, CHRISTOPHER CLUCKEY, and say: 1 This is an action for damages which exceeds the jurisdictional requirements of this Court. This Court has jurisdiction over the parties and subject matter of this action in that: (a) Plaintiff, MARSHALL WEBB, is a natural person and resident of Florida residing in Melbourne, Brevard County, Florida. (b) Defendant CHRISTOPHER CLUCKEY is a natural person and resident of Florida residing in Rockledge, Brevard County, Florida; (c) Venue is proper because the incident giving rise to the instant action occurred in Brevard County, Florida. FACTS COMMON TO ALL COUNTS 3 On or about September 8, 2023, defendant CHRISTOPHER CLUCKEY was operating a motor vehicle at or near Fiske Road in Rockledge, Brevard County, Florida. 4 Defendant CHRISTOPHER CLUCKEY was the owner of the vehicle he was operating at the above-described time and place. 1 Filing 194600184 VS 05-2024-CA-021340-XXCA-BC 5 At the time and place described above, defendant CHRISTOPHER CLUCKEY negligently operated and maintained his motor vehicle so that it collided with a vehicle driven by Plaintiff, MARSHALL WEBB, causing significant injuries. COUNTI NEGLIGENCE OF CHRISTOPHER CLUCKEY Plaintiff realleges and incorporates herein by reference each and every factual allegation as contained in Paragraphs 1 through 6 as if fully set forth herein. 7 Defendant, CHRISTOPHER CLUCKEY, negligently operated or maintained his 2010 Mazda vehicle causing it to impact the vehicle driven by Plaintiff, MARSHALL WEBB. 8 As a direct and proximate result of the negligence of the defendant CHRISTOPHER CLUCKEY, Plaintiff MARSHALL WEBB suffered significant bodily injury and resulting pain and suffering, impairment, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expenses of hospitalization, medical and nursing care and treatment, loss of earnings, aggravation and/or activation of a pre-existing condition or defect, and loss of ability to earn money. The injuries to the Plaintiff are permanent and he will continue to suffer the losses in the future. WHEREFORE, Plaintiff MARSHALL WEBB demands judgment for damages against defendant, CHRISTOPHER CLUCKEY, including costs of this action, and further demands a trial by jury on all issues so triable, and for such other relief as this Court deems just and proper. Filing 194600184 VS 05-2024-CA-021340-XXCA-BC DEMAND FOR JURY TRIAL Plaintiff, MARSHALL WEBB, demands a jury trial on all issues so triable of each and every one of the Counts set forth above. RESPECTFULLY submitted this DATED this 22nd day of March 2024. /s/ Michael Ghaly, ESQUIRE Michael Ghaly, Esq. Florida Bar No.: 122385 Dan Newlin Injury Attorneys 7335 W. Sand Lake Road, Suite 300 Orlando, FL 32819 Phone: 407-203-6565 Fax: 407-203-6565 Attorneys for Plaintiff PRINCIPAL EMAIL ADDRESS: Michael.Ghaly@newlinlaw.com Filing 194600184 VS 05-2024-CA-021340-XXCA-BC