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COUNT I – NEGLIGENCE AS TO CHARLENE REICH
ON BEHALF OF MARIA CARRANZA TORRES
5. On or about the 8th day of October, 2023, the Defendant, CHARLENE REICH,
owned and operated a vehicle in Bay County, Florida.
6. At that time and place, the Defendant, CHARLENE REICH, negligently operated
or maintained the motor vehicle so that it collided with a vehicle occupied by the Plaintiff, MARIA
CARRANZA TORRES, a resident of the State of Florida.
7. As a result, the Plaintiff, MARIA CARRANZA TORRES, 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 condition. The
losses are either permanent or continuing, and the Plaintiff, MARIA CARRANZA TORRES, will
suffer the losses in the future.
WHEREFORE, the Plaintiff, MARIA CARRANZA TORRES, demands judgment for
damages against Defendant, CHARLENE REICH, and a trial by jury of all issues triable as a right
by a jury.
COUNT II – NEGLIGENCE AS TO CHARLENE REICH
ON BEHALF OF ANTONIO GALLEGOS CARRANZA
The Plaintiff, ANTONIO GALLEGOS CARRANZA, repeats each allegation in
paragraphs one through seven and further alleges:
8. On or about the 8th of day of October, 2023, the Defendant, CHARLENE REICH,
owned and operated a vehicle in Bay County, Florida.
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9. At that time and place, the Defendant, CHARLENE REICH, negligently operated
or maintained the motor vehicle so that it collided with a vehicle occupied by the Plaintiff,
ANTONIO GALLEGOS CARRANZA, a resident of the State of Florida.
10. As a result, the Plaintiff, ANTONIO GALLEGOS CARRANZA, 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 condition. The
losses are either permanent or continuing, and the Plaintiff, ANTONIO GALLEGOS
CARRANZA, will suffer the losses in the future.
WHEREFORE, the Plaintiff, ANTONIO GALLEGOS CARRANZA, demands judgment
for damages against Defendant, CHARLENE REICH, and a trial by jury of all issues triable as a
right by a jury.
DEMAND FOR JURY TRIAL
Plaintiffs, MARIA CARRANZA TORRES and ANTONIO GALLEGOS CONTRERAS,
demands a trial by jury on all issues so triable, on this the 23rd day of May, 2024.
Respectfully submitted,
/s/Joseph Lancos, Esq.
Joseph B. Lancos, Esq.
Florida Bar No.: 124769
THE BRUNER LAW FIRM
3201 W-US Highway 98
Panama City, FL 32401
joseph@brunerfirm.com
priddy@brunerfirm.com
Phone: (850) 243-2222
Attorney for Plaintiffs
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COUNT I – NEGLIGENCE AS TO CHARLENE REICH ON BEHALF OF MARIA CARRANZA TORRES 5. On or about the 8th day of October, 2023, the Defendant, CHARLENE REICH, owned and operated a vehicle in Bay County, Florida. 6. At that time and place, the Defendant, CHARLENE REICH, negligently operated or maintained the motor vehicle so that it collided with a vehicle occupied by the Plaintiff, MARIA CARRANZA TORRES, a resident of the State of Florida. 7. As a result, the Plaintiff, MARIA CARRANZA TORRES, 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 condition. The losses are either permanent or continuing, and the Plaintiff, MARIA CARRANZA TORRES, will suffer the losses in the future. WHEREFORE, the Plaintiff, MARIA CARRANZA TORRES, demands judgment for damages against Defendant, CHARLENE REICH, and a trial by jury of all issues triable as a right by a jury. COUNT II – NEGLIGENCE AS TO CHARLENE REICH ON BEHALF OF ANTONIO GALLEGOS CARRANZA The Plaintiff, ANTONIO GALLEGOS CARRANZA, repeats each allegation in paragraphs one through seven and further alleges: 8. On or about the 8th of day of October, 2023, the Defendant, CHARLENE REICH, owned and operated a vehicle in Bay County, Florida. 2 9. At that time and place, the Defendant, CHARLENE REICH, negligently operated or maintained the motor vehicle so that it collided with a vehicle occupied by the Plaintiff, ANTONIO GALLEGOS CARRANZA, a resident of the State of Florida. 10. As a result, the Plaintiff, ANTONIO GALLEGOS CARRANZA, 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 condition. The losses are either permanent or continuing, and the Plaintiff, ANTONIO GALLEGOS CARRANZA, will suffer the losses in the future. WHEREFORE, the Plaintiff, ANTONIO GALLEGOS CARRANZA, demands judgment for damages against Defendant, CHARLENE REICH, and a trial by jury of all issues triable as a right by a jury. DEMAND FOR JURY TRIAL Plaintiffs, MARIA CARRANZA TORRES and ANTONIO GALLEGOS CONTRERAS, demands a trial by jury on all issues so triable, on this the 23rd day of May, 2024. Respectfully submitted, /s/Joseph Lancos, Esq. Joseph B. Lancos, Esq. Florida Bar No.: 124769 THE BRUNER LAW FIRM 3201 W-US Highway 98 Panama City, FL 32401 joseph@brunerfirm.com priddy@brunerfirm.com Phone: (850) 243-2222 Attorney for Plaintiffs 3