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Filing # 197436000 E-Filed 05/01/2024 05:24:39 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF THE
STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY
CIVIL ACTION
HALLIE TELFARE,
Plaintiff,
vs.
CASE NO.:
JILL SIMPSON, and DIVISION:
FREDERIC KEGELMEYER
Defendant. /
COMPLAINT
COMES NOW Plaintiff, HALLIE TELFARE, by and through the undersigned attorney,
and sues the Defendant, JILL SIMPSON and FREDERIC KEGELMEYER, and alleges:
JURISDICTION AND VENUE
1. That this is an action for damages in excess of FIFTY THOUSAND DOLLARS
($50,000.00).
2. That at all times pertinent to this action, the Plaintiff, HALLIE TELFARE, was a resident
of Brandon, Hillsborough County, Florida.
3. That at all times pertinent to this action, Defendant, JILL SIMPSON, was a resident of
the State of Florida. That at all times pertinent to this action, Defendant FREDERIC
KEGELMEYER, was a resident of the State of Florida.
4. That the cause of action alleged herein accrued in Brandon, Hillsborough County,
Florida.
COUNT I – NEGLIGENCE AGAINST JILL SIMPSON
5. Plaintiff adopts all allegations contained in paragraphs 1 through 4 as if fully set forth
herein.
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6. That on or about November 2, 2022, at approximately 11:55 A.M., Defendant, JILL
SIMPSON operated a motor vehicle and was traveling eastbound on Bloomingdale Avenue at or
near the intersection of Bell Shoals Road, in Hillsborough County, Florida.
7. That on or about November 2, 2022, at approximately 11:55 A.M., Plaintiff, HALLIE
TELFARE, was also operating a motor vehicle and was traveling eastbound on Bloomingdale
Avenue at or near the intersection of Bell Shoals Road, in Hillsborough County, Florida.
8. That at the aforementioned time and place, Defendant, JILL SIMPSON, did so carelessly
and negligently drive, manage, and operate their motor vehicle so as to cause a collision with the
motor vehicle being operated by Plaintiff, HALLIE TELFARE, thereby causing Plaintiff to
sustain personal injuries in and about the body as hereinafter alleged.
9. That on or about November 2, 2022, at approximately 11:55 A.M., Defendant, JILL
SIMPSON, owed to the public and to Plaintiff, HALLIE TELFARE, the duty to exercise
reasonable care and diligence in the operation of a motor vehicle and to abide by the traffic laws
of the State of Florida in the operation of that automobile.
10. That at the time and place described above, Defendant, JILL SIMPSON, breached their
duty owed to the public and to Plaintiff, HALLIE TELFARE, by:
a. failing to operate the aforementioned automobile with due care and diligence;
b. failing to operate the automobile at a reasonably safe speed for the given
conditions and surroundings described above;
c. failing to act or react as a reasonable and prudent operator of an automobile under
the given circumstances and conditions; and
d. carelessly operating the automobile and engaging in acts defined by Florida
Statutes as aggressive careless driving.
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11. That as a direct and proximate result of the carelessness and negligence of the Defendant,
JILL SIMPSON, Plaintiff, HALLIE TELFARE, sustained significant and permanent loss of an
important bodily function, significant and permanent scarring or disfigurement, permanent
injuries within a reasonable degree of medical probability, severe injuries to head, neck, back,
spine, shoulders, arms, legs, knees, joints, muscles, tendons, ligaments, nerves, soft tissues and
body as a whole; aggravated any pre-existing condition; suffered bodily injury and resulting pain
and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of
life, expense of hospitalization and medical and nursing care and treatment. Said losses are either
permanent or continuing in nature and Plaintiff, HALLIE TELFARE, will suffer the losses in the
future; Plaintiff, HALLIE TELFARE, has met or by the time of trial will have met the
requirements of Florida Statutes, Section 627.737.
WHEREFORE, Plaintiff, HALLIE TELFARE, demands judgment against Defendant,
JILL SIMPSON, for a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), plus
costs of these proceedings and any other remedy properly allowable by law and hereby demands
Trial by Jury on all issues so triable.
COUNT II – DANGEROUS INSTRUMENTALITY AGAINST FREDERIC
KEGELMEYER
11. Plaintiff adopts all allegations contained in paragraphs 1 through 4 as if fully set forth
herein.
12. That on or about November 2, 2022, at approximately 11:55 A.M., Defendant, JILL
SIMPSON operated a motor vehicle and was traveling eastbound on Bloomingdale Avenue at or
near the intersection of Bell Shoals Road, in Hillsborough County, Florida.
13. That on or about November 2, 2022, at approximately 11:55 A.M., Plaintiff, HALLIE
TELFARE, was also operating a motor vehicle and was traveling eastbound on Bloomingdale
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Avenue at or near the intersection of Bell Shoals Road, in Hillsborough County, Florida.
14. That at the aforementioned time and place, Defendant, JILL SIMPSON, did so carelessly
and negligently drive, manage and operate their motor vehicle so as to cause a collision with the
motor vehicle being operated by Plaintiff, HALLIE TELFARE, thereby causing Plaintiff to
sustain personal injuries in and about their body as hereinafter alleged.
15. That on or about November 2, 2022 at approximately 11:55 A.M., Defendant, JILL
SIMPSON, owed to the public and to Plaintiff, HALLIE TELFARE, the duty to exercise
reasonable care and diligence in the operation of a motor vehicle and to abide by the traffic laws
of the State of Florida in the operation of that automobile.
16. That at the time and place described above, Defendant, JILL SIMPSON, breached their
duty owed to the public and to Plaintiff, HALLIE TELFARE, by:
a. failing to operate the aforementioned automobile with due care and diligence;
b. failing to operate the automobile at a reasonably safe speed for the given
conditions and surroundings described above;
c. failing to act or react as a reasonable and prudent operator of an automobile
under
the given circumstances and conditions; and
d. carelessly operating the automobile and engaging in acts defined by Florida
Statutes as aggressive careless driving.
17. As the owner of the vehicle that Defendant, JILL SIMPSON, was driving, Defendant,
FREDERIC KEGELMEYER is vicariously liable for JILL SIMPSON’s negligence, as he
consented to Defendant JILL SIMPSON’s use of the vehicle at the time of the incident.
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17. That as a direct and proximate result of the carelessness and negligence of Defendant, JILL
SIMPSON, Plaintiff, HALLIE TELFARE, sustained significant and permanent loss of an
important bodily function, significant and permanent scarring or disfigurement, permanent
injuries within a reasonable degree of medical probability, severe injuries to head, neck, back,
spine, shoulders, arms, legs, knees, joints, muscles, tendons, ligaments, nerves, soft tissues and
body as a whole; aggravated any pre-existing condition; suffered bodily injury and resulting pain
and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of
life, expense of hospitalization and medical and nursing care and treatment. Said losses are either
permanent or continuing in nature and Plaintiff, HALLIE TELFARE, will suffer the losses in the
future; Plaintiff, HALLIE TELFARE, has met or by the time of trial will have met the
requirements of Florida Statutes, Section 627.737.
WHEREFORE, Plaintiff, HALLIE TELFARE, demands judgment against Defendant,
FREDERIC KEGELMEYER, for a sum in excess of FIFTY THOUSAND DOLLARS
($50,000.00), plus costs of these proceedings and any other remedy properly allowable by law
and hereby demands Trial by Jury on all issues so triable.
Date: May 1, 2024
/s/ Christopher N. Ligori
CHRISTOPHER N. LIGORI, ESQUIRE
CHRISTOPHER LIGORI & ASSOCIATES
117 S. Willow Ave.
Tampa, FL 33606
(813) 223-2929 : Telephone
(813) 251-6853: Facsimile
FLORIDA BAR # 0011045
Attorney for Plaintiff/22R0595
Service Email: Pleadings@ligorilaw.com
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Filing # 197436000 E-Filed 05/01/2024 05:24:39 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY CIVIL ACTION HALLIE TELFARE, Plaintiff, vs. CASE NO.: JILL SIMPSON, and DIVISION: FREDERIC KEGELMEYER Defendant. / COMPLAINT COMES NOW Plaintiff, HALLIE TELFARE, by and through the undersigned attorney, and sues the Defendant, JILL SIMPSON and FREDERIC KEGELMEYER, and alleges: JURISDICTION AND VENUE 1. That this is an action for damages in excess of FIFTY THOUSAND DOLLARS ($50,000.00). 2. That at all times pertinent to this action, the Plaintiff, HALLIE TELFARE, was a resident of Brandon, Hillsborough County, Florida. 3. That at all times pertinent to this action, Defendant, JILL SIMPSON, was a resident of the State of Florida. That at all times pertinent to this action, Defendant FREDERIC KEGELMEYER, was a resident of the State of Florida. 4. That the cause of action alleged herein accrued in Brandon, Hillsborough County, Florida. COUNT I – NEGLIGENCE AGAINST JILL SIMPSON 5. Plaintiff adopts all allegations contained in paragraphs 1 through 4 as if fully set forth herein. 1 5/1/2024 5:24 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 6. That on or about November 2, 2022, at approximately 11:55 A.M., Defendant, JILL SIMPSON operated a motor vehicle and was traveling eastbound on Bloomingdale Avenue at or near the intersection of Bell Shoals Road, in Hillsborough County, Florida. 7. That on or about November 2, 2022, at approximately 11:55 A.M., Plaintiff, HALLIE TELFARE, was also operating a motor vehicle and was traveling eastbound on Bloomingdale Avenue at or near the intersection of Bell Shoals Road, in Hillsborough County, Florida. 8. That at the aforementioned time and place, Defendant, JILL SIMPSON, did so carelessly and negligently drive, manage, and operate their motor vehicle so as to cause a collision with the motor vehicle being operated by Plaintiff, HALLIE TELFARE, thereby causing Plaintiff to sustain personal injuries in and about the body as hereinafter alleged. 9. That on or about November 2, 2022, at approximately 11:55 A.M., Defendant, JILL SIMPSON, owed to the public and to Plaintiff, HALLIE TELFARE, the duty to exercise reasonable care and diligence in the operation of a motor vehicle and to abide by the traffic laws of the State of Florida in the operation of that automobile. 10. That at the time and place described above, Defendant, JILL SIMPSON, breached their duty owed to the public and to Plaintiff, HALLIE TELFARE, by: a. failing to operate the aforementioned automobile with due care and diligence; b. failing to operate the automobile at a reasonably safe speed for the given conditions and surroundings described above; c. failing to act or react as a reasonable and prudent operator of an automobile under the given circumstances and conditions; and d. carelessly operating the automobile and engaging in acts defined by Florida Statutes as aggressive careless driving. 2 5/1/2024 5:24 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 11. That as a direct and proximate result of the carelessness and negligence of the Defendant, JILL SIMPSON, Plaintiff, HALLIE TELFARE, sustained significant and permanent loss of an important bodily function, significant and permanent scarring or disfigurement, permanent injuries within a reasonable degree of medical probability, severe injuries to head, neck, back, spine, shoulders, arms, legs, knees, joints, muscles, tendons, ligaments, nerves, soft tissues and body as a whole; aggravated any pre-existing condition; suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization and medical and nursing care and treatment. Said losses are either permanent or continuing in nature and Plaintiff, HALLIE TELFARE, will suffer the losses in the future; Plaintiff, HALLIE TELFARE, has met or by the time of trial will have met the requirements of Florida Statutes, Section 627.737. WHEREFORE, Plaintiff, HALLIE TELFARE, demands judgment against Defendant, JILL SIMPSON, for a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), plus costs of these proceedings and any other remedy properly allowable by law and hereby demands Trial by Jury on all issues so triable. COUNT II – DANGEROUS INSTRUMENTALITY AGAINST FREDERIC KEGELMEYER 11. Plaintiff adopts all allegations contained in paragraphs 1 through 4 as if fully set forth herein. 12. That on or about November 2, 2022, at approximately 11:55 A.M., Defendant, JILL SIMPSON operated a motor vehicle and was traveling eastbound on Bloomingdale Avenue at or near the intersection of Bell Shoals Road, in Hillsborough County, Florida. 13. That on or about November 2, 2022, at approximately 11:55 A.M., Plaintiff, HALLIE TELFARE, was also operating a motor vehicle and was traveling eastbound on Bloomingdale 3 5/1/2024 5:24 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 Avenue at or near the intersection of Bell Shoals Road, in Hillsborough County, Florida. 14. That at the aforementioned time and place, Defendant, JILL SIMPSON, did so carelessly and negligently drive, manage and operate their motor vehicle so as to cause a collision with the motor vehicle being operated by Plaintiff, HALLIE TELFARE, thereby causing Plaintiff to sustain personal injuries in and about their body as hereinafter alleged. 15. That on or about November 2, 2022 at approximately 11:55 A.M., Defendant, JILL SIMPSON, owed to the public and to Plaintiff, HALLIE TELFARE, the duty to exercise reasonable care and diligence in the operation of a motor vehicle and to abide by the traffic laws of the State of Florida in the operation of that automobile. 16. That at the time and place described above, Defendant, JILL SIMPSON, breached their duty owed to the public and to Plaintiff, HALLIE TELFARE, by: a. failing to operate the aforementioned automobile with due care and diligence; b. failing to operate the automobile at a reasonably safe speed for the given conditions and surroundings described above; c. failing to act or react as a reasonable and prudent operator of an automobile under the given circumstances and conditions; and d. carelessly operating the automobile and engaging in acts defined by Florida Statutes as aggressive careless driving. 17. As the owner of the vehicle that Defendant, JILL SIMPSON, was driving, Defendant, FREDERIC KEGELMEYER is vicariously liable for JILL SIMPSON’s negligence, as he consented to Defendant JILL SIMPSON’s use of the vehicle at the time of the incident. 4 5/1/2024 5:24 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4 17. That as a direct and proximate result of the carelessness and negligence of Defendant, JILL SIMPSON, Plaintiff, HALLIE TELFARE, sustained significant and permanent loss of an important bodily function, significant and permanent scarring or disfigurement, permanent injuries within a reasonable degree of medical probability, severe injuries to head, neck, back, spine, shoulders, arms, legs, knees, joints, muscles, tendons, ligaments, nerves, soft tissues and body as a whole; aggravated any pre-existing condition; suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization and medical and nursing care and treatment. Said losses are either permanent or continuing in nature and Plaintiff, HALLIE TELFARE, will suffer the losses in the future; Plaintiff, HALLIE TELFARE, has met or by the time of trial will have met the requirements of Florida Statutes, Section 627.737. WHEREFORE, Plaintiff, HALLIE TELFARE, demands judgment against Defendant, FREDERIC KEGELMEYER, for a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), plus costs of these proceedings and any other remedy properly allowable by law and hereby demands Trial by Jury on all issues so triable. Date: May 1, 2024 /s/ Christopher N. Ligori CHRISTOPHER N. LIGORI, ESQUIRE CHRISTOPHER LIGORI & ASSOCIATES 117 S. Willow Ave. Tampa, FL 33606 (813) 223-2929 : Telephone (813) 251-6853: Facsimile FLORIDA BAR # 0011045 Attorney for Plaintiff/22R0595 Service Email: Pleadings@ligorilaw.com 5 5/1/2024 5:24 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5