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Filing # 198561506 Filed os/7/2024 12:49:42 PM DIN: 3
IN THE CIRCUIT COURT OF THE SIXTH
JUDICIAL CIRCUIT OF FLORIDA, IN AND
FOR PASCO COUNTY. CIVIL DIVISION
RITA RODGERS,
Plaintiff,
CASE NO.:
vs.
TERENA JONES,
Defendant.
/
COMPLAINT
COMES NOW the Plaintiff, RITA RODGERS, by and through the undersigned
attorney and sues the Defendant, TERENA JONES, and will show unto this Honorable
Court as follows:
1 That this is an action for damages in excess of Fifty Thousand Dollars
($50,000.00).
2 That on or about December 7, 2023, Plaintiff, RITA RODGERS, was the
owner and operator of a vehicle in Dade City, East Pasco County, Florida.
3 That at the aforesaid time and place, Defendant, TERENA JONES, was
the owner and operator a vehicle traveling in Dade City, East Pasco County, Florida,
and did operate said vehicle in such a careless and negligent manner as to cause it to
collide with the vehicle in which the Plaintiff was a driver.
4 As a result, Plaintiff, RTA RODGERS, 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, and aggravation of a previously existing
Electronically Filed Pasco Case # 2024CA001336CAAXES 05/17/2024 12:49:42 PM
condition. The losses are either permanent or continuing in nature and Plaintiff will
suffer the losses in the future. Plaintiff's automobile was damaged and she lost the use
of it during the period required for its repair or replacement.
5 Defendant is being served through the offices of a Sheriff, an authorized
process server, or, in the alternative, after diligent search and inquiry, Defendant is a
non-resident of the State of Florida or Defendant is concealing her whereabouts and
avoiding service of process and are being served within the scope of Florida Statutes
48.161 and 48.171.
WHEREFORE, the Plaintiff, RITA RODGERS, sues the Defendant, TERENA
JONES, for all damages allowable under Florida Law, a sum in excess of Fifth
Thousand Dollars ($50,000.00), and respectfully demands a trial by jury.
ft
DREW BEN HUDGINS, ESQUIRE
Florida Bar No.: 325351
KENNETH A. MINIO, ESQUIRE
Florida Bar No.: 0021090
38453 5th Avenue
Zephyrhills, Florida 33542
Telephone: (813)788-5534
Facsimile: (813)783-6764
E-mail Designation:
drew@hudginslawfirm.net
ken@hudginslawfirm.net
tennis@hudginslawfirm.net
Attorney for Plaintiff
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Filing # 198561506 Filed os/7/2024 12:49:42 PM DIN: 3 IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR PASCO COUNTY. CIVIL DIVISION RITA RODGERS, Plaintiff, CASE NO.: vs. TERENA JONES, Defendant. / COMPLAINT COMES NOW the Plaintiff, RITA RODGERS, by and through the undersigned attorney and sues the Defendant, TERENA JONES, and will show unto this Honorable Court as follows: 1 That this is an action for damages in excess of Fifty Thousand Dollars ($50,000.00). 2 That on or about December 7, 2023, Plaintiff, RITA RODGERS, was the owner and operator of a vehicle in Dade City, East Pasco County, Florida. 3 That at the aforesaid time and place, Defendant, TERENA JONES, was the owner and operator a vehicle traveling in Dade City, East Pasco County, Florida, and did operate said vehicle in such a careless and negligent manner as to cause it to collide with the vehicle in which the Plaintiff was a driver. 4 As a result, Plaintiff, RTA RODGERS, 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, and aggravation of a previously existing Electronically Filed Pasco Case # 2024CA001336CAAXES 05/17/2024 12:49:42 PM condition. The losses are either permanent or continuing in nature and Plaintiff will suffer the losses in the future. Plaintiff's automobile was damaged and she lost the use of it during the period required for its repair or replacement. 5 Defendant is being served through the offices of a Sheriff, an authorized process server, or, in the alternative, after diligent search and inquiry, Defendant is a non-resident of the State of Florida or Defendant is concealing her whereabouts and avoiding service of process and are being served within the scope of Florida Statutes 48.161 and 48.171. WHEREFORE, the Plaintiff, RITA RODGERS, sues the Defendant, TERENA JONES, for all damages allowable under Florida Law, a sum in excess of Fifth Thousand Dollars ($50,000.00), and respectfully demands a trial by jury. ft DREW BEN HUDGINS, ESQUIRE Florida Bar No.: 325351 KENNETH A. MINIO, ESQUIRE Florida Bar No.: 0021090 38453 5th Avenue Zephyrhills, Florida 33542 Telephone: (813)788-5534 Facsimile: (813)783-6764 E-mail Designation: drew@hudginslawfirm.net ken@hudginslawfirm.net tennis@hudginslawfirm.net Attorney for Plaintiff