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Filing # 196545177 E-Filed 04/19/2024 11:12:59 AM
IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO:
CARIDAD MONTES PURON,
and ANTUAN PEREZ LOPEZ,
a minor, by and through his mother,
IRELYS LOPEZ MONTES, and IRELYS
LOPEZ MONTES, individually,
Plaintiffs,
vs.
JENNIFER LOPEZ ESTRADA,
Defendant.
____________________________________________________/
COMPLAINT AND DEMAND FOR JURY TRIAL
The Plaintiffs, CARIDAD MONTES PURON, ANTUAN PEREZ LOPEZ, by and through
his mother, IRELYS LOPEZ MONTES, and IRELYS LOPEZ MONTES, individually, sue the
Defendant, JENNIFER LOPEZ ESTRADA, and allege:
1. This is an action for damages in excess of the Fifty Thousand Dollars
($50,000.00) jurisdictional limits of this Court, exclusive of interest and cost.
2. That at all times hereinafter mentioned and at the time of the incident
complained of, The Plaintiffs, CARIDAD MONTES PURON, ANTUAN PEREZ LOPEZ, a
minor, Date of Birth: 02/28/2006, and IRELYS LOPEZ MONTES, ANTUAN PEREZ LOPEZ’s
mother, were and are residents of Miami-Dade County, Florida.
3. The Plaintiff, IRELYS LOPEZ MONTES, is the mother and natural
guardian of ANTUAN PEREZ LOPEZ, the minor Plaintiff.
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LAW OFFICES OF FELDMAN, BARON & VENTURA
100 ALMERIA AVE. SUITE 330
CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293
4. The Plaintiff, CARIDAD MONTES PURON, was at all times relevant over
the age of eighteen (18) and sui juris in all other respects.
5. The Defendant, JENNIFER LOPEZ ESTRADA, was at all times relevant,
a resident of Miami-Dade County, Florida, over the age of eighteen (18) and sui juris in all other
respects. Alternatively, it is alleged that the Defendant, JENNIFER LOPEZ ESTRADA, operated
a motor vehicle within the State of Florida and her present whereabouts are unknown and this
Court therefore has jurisdiction pursuant to the applicable Florida Statutes.
6. Venue is proper in this forum as Plaintiff’s cause of action occurred within
Miami-Dade County, Florida.
COUNT I – CLAIM OF NEGLIGENCE BY CARIDAD MONTES PURON
AGAINST JENNIFER LOPEZ ESTRADA
7. Paragraphs One (1) through Five (5) inclusive, are hereby re-alleged and
fully incorporated herein.
8. On or about September 28th, 2023, the Plaintiff, CARIDAD MONTES
PURON, was operating her motor vehicle northbound on Northwest 17th Avenue, at its intersection
with Northwest 38th Street, in Miami-Dade County, Florida. At the same time and place, the
Defendant, JENNIFER LOPEZ ESTRADA, was operating a 2013 Mini Cooper, bearing Florida
license plate BX42WR, southbound on Northwest 17th Avenue, at its intersection with Northwest
38th Street, in Miami-Dade County, Florida.
9. At the same time and place as ascribed above, as the Plaintiff, CARIDAD
MONTES PURON, was completing a left hand turn onto Northwest 38th Street on a steady green
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LAW OFFICES OF FELDMAN, BARON & VENTURA
100 ALMERIA AVE. SUITE 330
CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293
light, the Defendant, JENNIFER LOPEZ ESTRADA, made a right hand turn directly across the
Plaintiff’s right of way without yielding and causing a collision between their vehicles.
10. Defendant, JENNIFER LOPEZ ESTRADA, had a duty to the public in
general, and to the Plaintiff, CARIDAD MONTES PURON, in particular, to operate her motor
vehicle in a reasonable and prudent manner, which she failed to do, breaching her duty to the
Plaintiff.
11. As a direct and proximate result of the negligence of the Defendant,
JENNIFER LOPEZ ESTRADA, the Plaintiff, CARIDAD MONTES PURON, suffered bodily
injury and resulting pain, 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 and earning capacity, and aggravation of a previously existing condition. The losses are
either permanent or continuing in nature, and the Plaintiff, CARIDAD MONTES PURON, will
suffer the losses in the future.
WHEREFORE, the Plaintiff, CARIDAD MONTES PURON, individually,
demands judgment against the Defendant, ANETTE PIERRE BERNARD, as to all issues, and
further requests a trial by jury for all issues so triable by right, an award of court costs, and for all
other just and equitable relief that the Court deems necessary and proper under the circumstances.
COUNT II – CLAIM OF NEGLIGENCE BY ANTUAN PEREZ LOPEZ, by and through
his mother, IRELYS LOPEZ MONTES, AGAINST JENNIFER LOPEZ ESTRADA
12. Plaintiff, ANTUAN PEREZ LOPEZ, by and through his mother, IRELYS
LOPEZ MONTES, re-affirms and re-avers paragraphs 1-6 as if same were fully set forth herein.
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LAW OFFICES OF FELDMAN, BARON & VENTURA
100 ALMERIA AVE. SUITE 330
CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293
13. On or about September 28th, 2023, the minor Plaintiff, ANTUAN PEREZ
LOPEZ, was a passenger in a vehicle being operated by the Plaintiff CARIDAD MONTES
PURON, northbound on Northwest 17th Avenue, at its intersection with Northwest 38th Street, in
Miami-Dade County, Florida. At the same time and place, the Defendant, JENNIFER LOPEZ
ESTRADA, was operating a 2013 Mini Cooper, bearing Florida license plate BX42WR,
southbound on Northwest 17th Avenue, at its intersection with Northwest 38th Street, in Miami-
Dade County, Florida.
14. At the same time and place as ascribed above, as the Plaintiff, CARIDAD
MONTES PURON, was completing a left hand turn onto Northwest 38th Street on a steady green
light, the Defendant, JENNIFER LOPEZ ESTRADA, made a right hand turn directly across the
Plaintiff’s right of way without yielding and causing a collision between their vehicles.
15. Defendant, JENNIFER LOPEZ ESTRADA, had a duty to the public in
general, and to the minor Plaintiff, ANTUAN PEREZ LOPEZ, in particular, to operate her motor
vehicle in a reasonable and prudent manner, which she failed to do, breaching her duty to the
Plaintiff.
16. As a direct and proximate result of the negligence of the Defendant,
JENNIFER LOPEZ ESTRADA, the minor Plaintiff, ANTUAN PEREZ LOPEZ, suffered bodily
injury and resulting pain, 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 and earning capacity, and aggravation of a previously existing condition. The losses are
either permanent or continuing in nature, and the minor Plaintiff, ANTUAN PEREZ LOPEZ, will
suffer the losses in the future.
4|Page
LAW OFFICES OF FELDMAN, BARON & VENTURA
100 ALMERIA AVE. SUITE 330
CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293
WHEREFORE, the Plaintiff, ANTUAN PEREZ LOPEZ, by and through his
mother, IRELYS LOPEZ MONTES, demands judgment against the Defendant, JENNIFER
LOPEZ ESTRADA, as to all issues, and further requests a trial by jury for all issues so triable by
right, an award of court costs, and for all other just and equitable relief that the Court deems
necessary and proper under the circumstances.
COUNT III – CLAIM OF IRELYS LOPEZ MONTES FOR MEDICAL EXPENSES
AGAINST JENNIFER LOPEZ ESTRADA
17. Plaintiff, IRELYS LOPEZ MONTES, individually, re-affirms and re-avers
paragraphs 1-6 and 12-16 as if same were fully set forth herein.
18. As a result of the negligence of Defendant, JENNIFER LOPEZ ESTRADA,
which caused the minor Plaintiff, ANTUAN PEREZ LOPEZ, to suffer injuries, the minor Plaintiff
has incurred medical expenses in the past, and will incur medical expenses in the future.
19. IRELYS LOPEZ MONTES, as mother and natural guardian of ANTUAN
PEREZ LOPEZ, is responsible for, and has incurred significant medical expenses for the care and
treatment of ANTUAN PEREZ LOPEZ as a result of this incident and will remain responsible for
ANTUAN PEREZ LOPEZ’s medical bills until he reaches his age of majority.
WHEREFORE, the Plaintiff, IRELYS LOPEZ MONTES, individually, demands
judgment against Defendant, JENNIFER LOPEZ ESTRADA as to all issues, and Plaintiff further
requests a trial by jury for all issues so triable by right, an award of court costs, and for all other
just and equitable relief that the court deems necessary and proper under the circumstances.
Dated this 19th day of April 2024.
Respectfully Submitted,
By: /S/ Eric B. Feldman
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LAW OFFICES OF FELDMAN, BARON & VENTURA
100 ALMERIA AVE. SUITE 330
CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293
Eric B. Feldman, Esq.
Florida Bar No. 288357
Law Offices of Feldman, Baron & Ventura
100 Almeria Avenue, Suite 330
Coral Gables, Florida 33134
Telephone (305) 443-5235
Facsimile: (305) 443-4293
Primary Email: ericbfeldman@hotmail.com
Secondary: zenaida@fbvlawyers.com
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LAW OFFICES OF FELDMAN, BARON & VENTURA
100 ALMERIA AVE. SUITE 330
CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293
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Filing # 196545177 E-Filed 04/19/2024 11:12:59 AM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO: CARIDAD MONTES PURON, and ANTUAN PEREZ LOPEZ, a minor, by and through his mother, IRELYS LOPEZ MONTES, and IRELYS LOPEZ MONTES, individually, Plaintiffs, vs. JENNIFER LOPEZ ESTRADA, Defendant. ____________________________________________________/ COMPLAINT AND DEMAND FOR JURY TRIAL The Plaintiffs, CARIDAD MONTES PURON, ANTUAN PEREZ LOPEZ, by and through his mother, IRELYS LOPEZ MONTES, and IRELYS LOPEZ MONTES, individually, sue the Defendant, JENNIFER LOPEZ ESTRADA, and allege: 1. This is an action for damages in excess of the Fifty Thousand Dollars ($50,000.00) jurisdictional limits of this Court, exclusive of interest and cost. 2. That at all times hereinafter mentioned and at the time of the incident complained of, The Plaintiffs, CARIDAD MONTES PURON, ANTUAN PEREZ LOPEZ, a minor, Date of Birth: 02/28/2006, and IRELYS LOPEZ MONTES, ANTUAN PEREZ LOPEZ’s mother, were and are residents of Miami-Dade County, Florida. 3. The Plaintiff, IRELYS LOPEZ MONTES, is the mother and natural guardian of ANTUAN PEREZ LOPEZ, the minor Plaintiff. 1|Page LAW OFFICES OF FELDMAN, BARON & VENTURA 100 ALMERIA AVE. SUITE 330 CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293 4. The Plaintiff, CARIDAD MONTES PURON, was at all times relevant over the age of eighteen (18) and sui juris in all other respects. 5. The Defendant, JENNIFER LOPEZ ESTRADA, was at all times relevant, a resident of Miami-Dade County, Florida, over the age of eighteen (18) and sui juris in all other respects. Alternatively, it is alleged that the Defendant, JENNIFER LOPEZ ESTRADA, operated a motor vehicle within the State of Florida and her present whereabouts are unknown and this Court therefore has jurisdiction pursuant to the applicable Florida Statutes. 6. Venue is proper in this forum as Plaintiff’s cause of action occurred within Miami-Dade County, Florida. COUNT I – CLAIM OF NEGLIGENCE BY CARIDAD MONTES PURON AGAINST JENNIFER LOPEZ ESTRADA 7. Paragraphs One (1) through Five (5) inclusive, are hereby re-alleged and fully incorporated herein. 8. On or about September 28th, 2023, the Plaintiff, CARIDAD MONTES PURON, was operating her motor vehicle northbound on Northwest 17th Avenue, at its intersection with Northwest 38th Street, in Miami-Dade County, Florida. At the same time and place, the Defendant, JENNIFER LOPEZ ESTRADA, was operating a 2013 Mini Cooper, bearing Florida license plate BX42WR, southbound on Northwest 17th Avenue, at its intersection with Northwest 38th Street, in Miami-Dade County, Florida. 9. At the same time and place as ascribed above, as the Plaintiff, CARIDAD MONTES PURON, was completing a left hand turn onto Northwest 38th Street on a steady green 2|Page LAW OFFICES OF FELDMAN, BARON & VENTURA 100 ALMERIA AVE. SUITE 330 CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293 light, the Defendant, JENNIFER LOPEZ ESTRADA, made a right hand turn directly across the Plaintiff’s right of way without yielding and causing a collision between their vehicles. 10. Defendant, JENNIFER LOPEZ ESTRADA, had a duty to the public in general, and to the Plaintiff, CARIDAD MONTES PURON, in particular, to operate her motor vehicle in a reasonable and prudent manner, which she failed to do, breaching her duty to the Plaintiff. 11. As a direct and proximate result of the negligence of the Defendant, JENNIFER LOPEZ ESTRADA, the Plaintiff, CARIDAD MONTES PURON, suffered bodily injury and resulting pain, 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 and earning capacity, and aggravation of a previously existing condition. The losses are either permanent or continuing in nature, and the Plaintiff, CARIDAD MONTES PURON, will suffer the losses in the future. WHEREFORE, the Plaintiff, CARIDAD MONTES PURON, individually, demands judgment against the Defendant, ANETTE PIERRE BERNARD, as to all issues, and further requests a trial by jury for all issues so triable by right, an award of court costs, and for all other just and equitable relief that the Court deems necessary and proper under the circumstances. COUNT II – CLAIM OF NEGLIGENCE BY ANTUAN PEREZ LOPEZ, by and through his mother, IRELYS LOPEZ MONTES, AGAINST JENNIFER LOPEZ ESTRADA 12. Plaintiff, ANTUAN PEREZ LOPEZ, by and through his mother, IRELYS LOPEZ MONTES, re-affirms and re-avers paragraphs 1-6 as if same were fully set forth herein. 3|Page LAW OFFICES OF FELDMAN, BARON & VENTURA 100 ALMERIA AVE. SUITE 330 CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293 13. On or about September 28th, 2023, the minor Plaintiff, ANTUAN PEREZ LOPEZ, was a passenger in a vehicle being operated by the Plaintiff CARIDAD MONTES PURON, northbound on Northwest 17th Avenue, at its intersection with Northwest 38th Street, in Miami-Dade County, Florida. At the same time and place, the Defendant, JENNIFER LOPEZ ESTRADA, was operating a 2013 Mini Cooper, bearing Florida license plate BX42WR, southbound on Northwest 17th Avenue, at its intersection with Northwest 38th Street, in Miami- Dade County, Florida. 14. At the same time and place as ascribed above, as the Plaintiff, CARIDAD MONTES PURON, was completing a left hand turn onto Northwest 38th Street on a steady green light, the Defendant, JENNIFER LOPEZ ESTRADA, made a right hand turn directly across the Plaintiff’s right of way without yielding and causing a collision between their vehicles. 15. Defendant, JENNIFER LOPEZ ESTRADA, had a duty to the public in general, and to the minor Plaintiff, ANTUAN PEREZ LOPEZ, in particular, to operate her motor vehicle in a reasonable and prudent manner, which she failed to do, breaching her duty to the Plaintiff. 16. As a direct and proximate result of the negligence of the Defendant, JENNIFER LOPEZ ESTRADA, the minor Plaintiff, ANTUAN PEREZ LOPEZ, suffered bodily injury and resulting pain, 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 and earning capacity, and aggravation of a previously existing condition. The losses are either permanent or continuing in nature, and the minor Plaintiff, ANTUAN PEREZ LOPEZ, will suffer the losses in the future. 4|Page LAW OFFICES OF FELDMAN, BARON & VENTURA 100 ALMERIA AVE. SUITE 330 CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293 WHEREFORE, the Plaintiff, ANTUAN PEREZ LOPEZ, by and through his mother, IRELYS LOPEZ MONTES, demands judgment against the Defendant, JENNIFER LOPEZ ESTRADA, as to all issues, and further requests a trial by jury for all issues so triable by right, an award of court costs, and for all other just and equitable relief that the Court deems necessary and proper under the circumstances. COUNT III – CLAIM OF IRELYS LOPEZ MONTES FOR MEDICAL EXPENSES AGAINST JENNIFER LOPEZ ESTRADA 17. Plaintiff, IRELYS LOPEZ MONTES, individually, re-affirms and re-avers paragraphs 1-6 and 12-16 as if same were fully set forth herein. 18. As a result of the negligence of Defendant, JENNIFER LOPEZ ESTRADA, which caused the minor Plaintiff, ANTUAN PEREZ LOPEZ, to suffer injuries, the minor Plaintiff has incurred medical expenses in the past, and will incur medical expenses in the future. 19. IRELYS LOPEZ MONTES, as mother and natural guardian of ANTUAN PEREZ LOPEZ, is responsible for, and has incurred significant medical expenses for the care and treatment of ANTUAN PEREZ LOPEZ as a result of this incident and will remain responsible for ANTUAN PEREZ LOPEZ’s medical bills until he reaches his age of majority. WHEREFORE, the Plaintiff, IRELYS LOPEZ MONTES, individually, demands judgment against Defendant, JENNIFER LOPEZ ESTRADA as to all issues, and Plaintiff further requests a trial by jury for all issues so triable by right, an award of court costs, and for all other just and equitable relief that the court deems necessary and proper under the circumstances. Dated this 19th day of April 2024. Respectfully Submitted, By: /S/ Eric B. Feldman 5|Page LAW OFFICES OF FELDMAN, BARON & VENTURA 100 ALMERIA AVE. SUITE 330 CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293 Eric B. Feldman, Esq. Florida Bar No. 288357 Law Offices of Feldman, Baron & Ventura 100 Almeria Avenue, Suite 330 Coral Gables, Florida 33134 Telephone (305) 443-5235 Facsimile: (305) 443-4293 Primary Email: ericbfeldman@hotmail.com Secondary: zenaida@fbvlawyers.com 6|Page LAW OFFICES OF FELDMAN, BARON & VENTURA 100 ALMERIA AVE. SUITE 330 CORAL GABLES, FL 33134: P:(305)-443-5235: F: (305)443-4293