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Filing # 196180061 E-Filed 04/15/2024 11:35:45 AM
IN THE CIRCUIT COURT OF THE THIRTEETHJUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
Case No.:
Division:
YADIRA ALVAREZ VERDECIA, individually,
Plaintiff,
vs.
PHOEBE JOSEPH, individually,
Defendant.
_________________________________________/
COMPLAINT
COMES NOW, Plaintiff, YADIRA ALVAREZ VERDECIA, hereinafter referred to
as “Plaintiff”, files this Complaint against PHOEBE JOSEPH, hereinafter referred to as
“Defendant”, and alleges:
PARTIES
1. Plaintiff, YADIRA ALVAREZ VERDENCIA, is an individual and resides in
HillsboroughCounty, Florida and is sui juris.
2. Defendant, PHOEBE JOSEPH, is an individual and resides in Palm Beach
County, Florida and is sui juris.
JURISDICTIONAL STATEMENT
3. This is an action for motor vehicle negligence. This action is a matter within the
jurisdiction of the court in accordance with Section 26.012(2)(a) of the Florida Statutes.
4. This is an action for damages in excess of $50,000.00 excluding interest, costs and
attorney's feesand is within the jurisdictionin accordance with Section 34.01(1)(c)of the Florida
Statutes of the Circuit Court of Hillsborough County, Florida.
VENUE
5. Venue in HillsboroughCounty, Florida is proper in this action under Section
47.011 of the Florida Statutes because the motor vehicle collision giving rise to this action
occurred in this county.
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FACTS IN SUPPORT OF CLAIMS
6. On or about March 21st, 2023, Plaintiff, YADIRA ALVAREZ VERDECIA,
operated, owned or maintained a motor vehicle on South Armenia Avenue, Hillsborough
County, Florida.
7. That at the aforesaid time and place, the Defendant,PHOEBE JOSEPH,
negligently owned, operated and or maintained a2021 HONDA, so as to cause it to collide with
the motor vehicle that the Plaintiff, YADIRA ALVAREZ VERDECIA, was driving.
8. As a direct and proximate 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 money, aggravation of a previously existing condition, permanent disfigurement
and scarring. The losses are either permanent or continuing and Plaintiffs will suffer the losses
in the future. Plaintiff, YADIRA ALVAREZ VERDECIA’sautomobile was damaged and
Plaintifflost the use of it during the period required for its repair or replacement.
COUNT 1
MOTOR VEHICLE NEGLIGENCE
9. Plaintiffadopts by reference, as if set out fully and completely in this Count, the
following statements of this Complaint: Paragraphs 1 through 8.
10. That at the aforesaid time and place, the Defendant, PHOEBE JOSEPH,
negligently owned, operated and or maintained a 2021 HONDA, so as to cause it to collide with
the motor vehicle that the Plaintiff, YADIRA ALVAREZ VERDECIA, was driving.
11. At that time and place, Defendant negligently operated or maintained the motor
vehicle so that it collided with Plaintiff, YADIRA ALVAREZ VERDECIA’s motor vehicle.
DEMAND FOR JURY TRIAL
12. Plaintiff demands a trial of this action by jury.
4/15/2024 11:35 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
DEMAND FOR JUDGMENT
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.
MarjorieUzquiano, Esq.
Florida Bar No.: 110457
Uzquiano Law Group, P.A.
Attorney for Plaintiff
7925 NW 12 St., Suite 229
Miami, FL 33126
(305) 441-0240 Tel.
(305) 441-0280 Fax
Uzquianolawgroup@gmail.com
4/15/2024 11:35 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
Preview
Filing # 196180061 E-Filed 04/15/2024 11:35:45 AM IN THE CIRCUIT COURT OF THE THIRTEETHJUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA Case No.: Division: YADIRA ALVAREZ VERDECIA, individually, Plaintiff, vs. PHOEBE JOSEPH, individually, Defendant. _________________________________________/ COMPLAINT COMES NOW, Plaintiff, YADIRA ALVAREZ VERDECIA, hereinafter referred to as “Plaintiff”, files this Complaint against PHOEBE JOSEPH, hereinafter referred to as “Defendant”, and alleges: PARTIES 1. Plaintiff, YADIRA ALVAREZ VERDENCIA, is an individual and resides in HillsboroughCounty, Florida and is sui juris. 2. Defendant, PHOEBE JOSEPH, is an individual and resides in Palm Beach County, Florida and is sui juris. JURISDICTIONAL STATEMENT 3. This is an action for motor vehicle negligence. This action is a matter within the jurisdiction of the court in accordance with Section 26.012(2)(a) of the Florida Statutes. 4. This is an action for damages in excess of $50,000.00 excluding interest, costs and attorney's feesand is within the jurisdictionin accordance with Section 34.01(1)(c)of the Florida Statutes of the Circuit Court of Hillsborough County, Florida. VENUE 5. Venue in HillsboroughCounty, Florida is proper in this action under Section 47.011 of the Florida Statutes because the motor vehicle collision giving rise to this action occurred in this county. 4/15/2024 11:35 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 FACTS IN SUPPORT OF CLAIMS 6. On or about March 21st, 2023, Plaintiff, YADIRA ALVAREZ VERDECIA, operated, owned or maintained a motor vehicle on South Armenia Avenue, Hillsborough County, Florida. 7. That at the aforesaid time and place, the Defendant,PHOEBE JOSEPH, negligently owned, operated and or maintained a2021 HONDA, so as to cause it to collide with the motor vehicle that the Plaintiff, YADIRA ALVAREZ VERDECIA, was driving. 8. As a direct and proximate 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 money, aggravation of a previously existing condition, permanent disfigurement and scarring. The losses are either permanent or continuing and Plaintiffs will suffer the losses in the future. Plaintiff, YADIRA ALVAREZ VERDECIA’sautomobile was damaged and Plaintifflost the use of it during the period required for its repair or replacement. COUNT 1 MOTOR VEHICLE NEGLIGENCE 9. Plaintiffadopts by reference, as if set out fully and completely in this Count, the following statements of this Complaint: Paragraphs 1 through 8. 10. That at the aforesaid time and place, the Defendant, PHOEBE JOSEPH, negligently owned, operated and or maintained a 2021 HONDA, so as to cause it to collide with the motor vehicle that the Plaintiff, YADIRA ALVAREZ VERDECIA, was driving. 11. At that time and place, Defendant negligently operated or maintained the motor vehicle so that it collided with Plaintiff, YADIRA ALVAREZ VERDECIA’s motor vehicle. DEMAND FOR JURY TRIAL 12. Plaintiff demands a trial of this action by jury. 4/15/2024 11:35 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 DEMAND FOR JUDGMENT 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. MarjorieUzquiano, Esq. Florida Bar No.: 110457 Uzquiano Law Group, P.A. Attorney for Plaintiff 7925 NW 12 St., Suite 229 Miami, FL 33126 (305) 441-0240 Tel. (305) 441-0280 Fax Uzquianolawgroup@gmail.com 4/15/2024 11:35 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3