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**** CASE NUMBER: 502024CA003146XXXAMB Div: AK ****
Filing # 195522784 E-Filed 04/04/2024 04:33:37 PM
IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT,
IN AND FOR PALM BEACH COUNTY, FLORIDA
OLIVIER MAXIS
)
Plaintiff, ) Case No.
)
-vs- )
)
RICHARD CALAS )
)
Defendant. )
COMPLAINT
COMES NOW, the Plaintiff, OLIVIER MAXIS, by and through the undersigned counsel
and hereby sues the Defendant, RICHARD CALAS, and alleges:
GENERAL ALLEGATIONS
1. This is an action for damages in excess of Fifty Thousand Dollars ($50,000.01), exclusive
of interest, costs and attorneys’ fees.
2. That at all times material to the cause herein, the Plaintiff, OLIVIER MAXIS, was and is
a resident of Palm Beach County, Florida.
3. That at all times material to the cause herein, the Defendant, RICHARD CALAS, was a
resident of Palm Beach County, Florida.
4. On or about August 12, 2023, the Defendant, RICHARD CALAS, was the owner and
operator of a 2021 Toyota Corolla which was being driven on or around Forest Hill Blvd. and S.
Jog Rd. in Palm Beach County, Florida.
Page 1 of 3
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 04/04/2024 04:33:37 PM
COUNT I – NEGLIGENCE OF RICHARD CALAS
Plaintiff realleges and reavers all of the general allegations contained in Paragraphs 1 through
4 above as though fully set forth herein.
5. That at the above time and place, the Defendant, RICHARD CALAS, did owe a duty of
care to the Plaintiff, OLIVIER MAXIS, to use reasonable care and/or caution to property
maintain, operate and control the motor vehicle he was operating.
6. That at said time and place, the Defendant, RICHARD CALAS, did breach the above-
mentioned duty by negligently and/or carelessly operating and/or maintaining said motor vehicle
so as to cause it to strike the Plaintiff, OLIVIER MAXIS.
7. That as a direct, proximate and foreseeable result of the negligence of the Defendant,
RICHARD CALAS, the Plaintiff, OLIVIER MAXIS, suffered bodily injury and resulting pain
and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of
life, expenses of hospitalization, medical and nursing care, loss of wages in the past and future,
and treatment and aggravation of a preexisting condition. The losses are either permanent or
continuing in nature and the Plaintiff, OLIVIER MAXIS, will suffer losses in the future.
Plaintiff’s automobile was damaged and he lost the use of it during the period required for its
repair or replacement.
WHEREFORE plaintiff demands a jury trial of this action, and further demands judgment
against defendant for general damages, and for such other and further relief, in law or in equity,
to which plaintiff may be justly entitled.
/s/ Andrew Agnini
Andrew J. Agnini, Esq.
Frankl Kominsky Injury Lawyers
Attorneys for the Plaintiff
2240 Woolbright Road, Suite 201
Boynton Beach, FL 33426
Phone: (561) 800-8000
Page 2 of 3
Email: filing@fklegal.com
Fla. Bar No.: 90845
Page 3 of 3
Preview
**** CASE NUMBER: 502024CA003146XXXAMB Div: AK **** Filing # 195522784 E-Filed 04/04/2024 04:33:37 PM IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA OLIVIER MAXIS ) Plaintiff, ) Case No. ) -vs- ) ) RICHARD CALAS ) ) Defendant. ) COMPLAINT COMES NOW, the Plaintiff, OLIVIER MAXIS, by and through the undersigned counsel and hereby sues the Defendant, RICHARD CALAS, and alleges: GENERAL ALLEGATIONS 1. This is an action for damages in excess of Fifty Thousand Dollars ($50,000.01), exclusive of interest, costs and attorneys’ fees. 2. That at all times material to the cause herein, the Plaintiff, OLIVIER MAXIS, was and is a resident of Palm Beach County, Florida. 3. That at all times material to the cause herein, the Defendant, RICHARD CALAS, was a resident of Palm Beach County, Florida. 4. On or about August 12, 2023, the Defendant, RICHARD CALAS, was the owner and operator of a 2021 Toyota Corolla which was being driven on or around Forest Hill Blvd. and S. Jog Rd. in Palm Beach County, Florida. Page 1 of 3 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 04/04/2024 04:33:37 PM COUNT I – NEGLIGENCE OF RICHARD CALAS Plaintiff realleges and reavers all of the general allegations contained in Paragraphs 1 through 4 above as though fully set forth herein. 5. That at the above time and place, the Defendant, RICHARD CALAS, did owe a duty of care to the Plaintiff, OLIVIER MAXIS, to use reasonable care and/or caution to property maintain, operate and control the motor vehicle he was operating. 6. That at said time and place, the Defendant, RICHARD CALAS, did breach the above- mentioned duty by negligently and/or carelessly operating and/or maintaining said motor vehicle so as to cause it to strike the Plaintiff, OLIVIER MAXIS. 7. That as a direct, proximate and foreseeable result of the negligence of the Defendant, RICHARD CALAS, the Plaintiff, OLIVIER MAXIS, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expenses of hospitalization, medical and nursing care, loss of wages in the past and future, and treatment and aggravation of a preexisting condition. The losses are either permanent or continuing in nature and the Plaintiff, OLIVIER MAXIS, will suffer losses in the future. Plaintiff’s automobile was damaged and he lost the use of it during the period required for its repair or replacement. WHEREFORE plaintiff demands a jury trial of this action, and further demands judgment against defendant for general damages, and for such other and further relief, in law or in equity, to which plaintiff may be justly entitled. /s/ Andrew Agnini Andrew J. Agnini, Esq. Frankl Kominsky Injury Lawyers Attorneys for the Plaintiff 2240 Woolbright Road, Suite 201 Boynton Beach, FL 33426 Phone: (561) 800-8000 Page 2 of 3 Email: filing@fklegal.com Fla. Bar No.: 90845 Page 3 of 3