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Filing # 199813837 E-Filed 06/04/2024 03:01:37 PM
IN THE CIRCUIT COURT OF THE TWELETH JUDICIAL CIRCUIT
IN AND FOR MANATEE COUNTY, FLORIDA
KIMBERLY MARIE KARL,
Plaintiff,
Vv. Case No.:
RUTHANN REBECCA WILLIAMS as
personal representative for the Estate of
Chad Daniel Henry Williams
a/k/a Chad Williams, deceased,
Defendant.
if
COMPLAINT
Plaintiff KIMBERLY MARIE KARL by and through her undersigned attorneys, sues
Defendant RUTHANN REBECCA WILLIAMS as personal representative for the Estate of Chad
Daniel Henry Williams a/k/a Chad Williams and alleges:
1 This is an action for damages in excess of Fifty Thousand Dollars ($50,000.00), exclusive
of interest, costs, and attorney's fees,
2 The accident which constitutes the subject matter of this action occurred in Manatee
County, Florida.
3 On or about February 25, 2024, Chad Daniel Henry Williams a/k/a Chad Williams owned
and operated a motor vehicle, specifically a motorcycle, in Manatee County, Florida.
4 On or about February 25, 2024, KIMBERLY MARIE KARL was a passenger on the
motorcycle owned and operated by Chad Daniel Henry Williams a/k/a Chad Williams in Manatee
County, Florida.
5 At all times relevant herein, Plaintiff KIMBERLY MARIE KARL was a resident of
Manatee County, Florida.
"2024CA000897AX" 199813837 Filed at Manatee County Clerk 06/04/2024 03:01:36 PM EDT
6 At all times relevant herein, Chad Daniel Henry Williams a/k/a Chad Williams, was a
resident of Manatee County, Florida.
7 On or about February 25, 2024, Chad Daniel Henry Williams a/k/a Chad Williams
negligently operated and/or maintained said motorcycle so that he lost control of it, causing it to
leave the roadway, eventually running off the roadway.
8 At the time Chad Daniel Henry Williams a/k/a Chad Williams operated and/or maintained
said motorcycle, he was driving under the influence of alechol as defined by F.S. 316.193.
9. On April 12, 2024, Chad Daniel Henry Williams a/k/a Chad Williams died, in part, from
the injuries sustained in the February 25, 2024 crash,
10. As a direct result of deceased driver Chad Daniel Henry Williams a/k/a Chad WilBams’
negligence, Plaintiff KIMBERLY MARIE KARL suffered bodily injuries and resulting pain and
suffering, disability, disfigurement, scarring, mental anguish, loss of capacity for the enjoyment of
life, expenses of hospitalization, medical, chiropractic and nursing care and treatment, loss of
wages, loss of earning capacity in the future, and aggravation of a previously existing condition.
The losses are permanent in nature and/or continuing, and Plaintiff KIMBERLY MARIE KARL
will suffer these losses in the future.
il. On or about May 15, 2024 Defendant RUTHANN REBECCA WILLIAMS was appointed
Personal Representative for the Estate of deceased driver Chad Daniel Henry Williams a/k/a Chad
Williams in Manatee County, Florida, in Case No. 2024 CP 001112AX giving her full power fo
administer the estate according to law; to ask, demand, sue for, recover and receive the property
of the decedent; to pay the debts of the decedent as far as the assets of the estate will permit and
the law directs; and to make distribution of the estate according to law. See Order Appointing
"2024CA000897AX" 199813837 Filed at Manatee County Clerk 06/04/2024 03:01:36 PM EDT
Personal Representative attached hereto as Exhibit “A” and Letters of Administration attached
hereto as Exhibit “B”.
WHEREFORE, Plaintiff KIMBERLY MARIE KARL demands judgment against
Defendant RUTHANN REBECCA WILLIAMS as personal representative for the Estate of Chad
Daniel Henry Williams a/k/a Chad Williams, the deceased driver for damages, interest, and costs,
if appropriate, a trial by jury of all issues so triable and any other further relief that the Court deems
just and proper in accordance with the law,
Dated this ‘ { day of June 2024.
Gregory S. Hagopian, Esq
FBN: 980481
Gallagher & Hagopian, PI.
7341 North Tamiami Trail
Sarasota, FL 34243
(941) 280-4878
(941) 727-6933 fax
gh@hurtbyaccident.com
Counsel for Plaintiff
"2024CA000897AX" 199813837 Filed at Manatee County Clerk 06/04/2024 03:01:36 PM EDT
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Filing # 199813837 E-Filed 06/04/2024 03:01:37 PM IN THE CIRCUIT COURT OF THE TWELETH JUDICIAL CIRCUIT IN AND FOR MANATEE COUNTY, FLORIDA KIMBERLY MARIE KARL, Plaintiff, Vv. Case No.: RUTHANN REBECCA WILLIAMS as personal representative for the Estate of Chad Daniel Henry Williams a/k/a Chad Williams, deceased, Defendant. if COMPLAINT Plaintiff KIMBERLY MARIE KARL by and through her undersigned attorneys, sues Defendant RUTHANN REBECCA WILLIAMS as personal representative for the Estate of Chad Daniel Henry Williams a/k/a Chad Williams and alleges: 1 This is an action for damages in excess of Fifty Thousand Dollars ($50,000.00), exclusive of interest, costs, and attorney's fees, 2 The accident which constitutes the subject matter of this action occurred in Manatee County, Florida. 3 On or about February 25, 2024, Chad Daniel Henry Williams a/k/a Chad Williams owned and operated a motor vehicle, specifically a motorcycle, in Manatee County, Florida. 4 On or about February 25, 2024, KIMBERLY MARIE KARL was a passenger on the motorcycle owned and operated by Chad Daniel Henry Williams a/k/a Chad Williams in Manatee County, Florida. 5 At all times relevant herein, Plaintiff KIMBERLY MARIE KARL was a resident of Manatee County, Florida. "2024CA000897AX" 199813837 Filed at Manatee County Clerk 06/04/2024 03:01:36 PM EDT 6 At all times relevant herein, Chad Daniel Henry Williams a/k/a Chad Williams, was a resident of Manatee County, Florida. 7 On or about February 25, 2024, Chad Daniel Henry Williams a/k/a Chad Williams negligently operated and/or maintained said motorcycle so that he lost control of it, causing it to leave the roadway, eventually running off the roadway. 8 At the time Chad Daniel Henry Williams a/k/a Chad Williams operated and/or maintained said motorcycle, he was driving under the influence of alechol as defined by F.S. 316.193. 9. On April 12, 2024, Chad Daniel Henry Williams a/k/a Chad Williams died, in part, from the injuries sustained in the February 25, 2024 crash, 10. As a direct result of deceased driver Chad Daniel Henry Williams a/k/a Chad WilBams’ negligence, Plaintiff KIMBERLY MARIE KARL suffered bodily injuries and resulting pain and suffering, disability, disfigurement, scarring, mental anguish, loss of capacity for the enjoyment of life, expenses of hospitalization, medical, chiropractic and nursing care and treatment, loss of wages, loss of earning capacity in the future, and aggravation of a previously existing condition. The losses are permanent in nature and/or continuing, and Plaintiff KIMBERLY MARIE KARL will suffer these losses in the future. il. On or about May 15, 2024 Defendant RUTHANN REBECCA WILLIAMS was appointed Personal Representative for the Estate of deceased driver Chad Daniel Henry Williams a/k/a Chad Williams in Manatee County, Florida, in Case No. 2024 CP 001112AX giving her full power fo administer the estate according to law; to ask, demand, sue for, recover and receive the property of the decedent; to pay the debts of the decedent as far as the assets of the estate will permit and the law directs; and to make distribution of the estate according to law. See Order Appointing "2024CA000897AX" 199813837 Filed at Manatee County Clerk 06/04/2024 03:01:36 PM EDT Personal Representative attached hereto as Exhibit “A” and Letters of Administration attached hereto as Exhibit “B”. WHEREFORE, Plaintiff KIMBERLY MARIE KARL demands judgment against Defendant RUTHANN REBECCA WILLIAMS as personal representative for the Estate of Chad Daniel Henry Williams a/k/a Chad Williams, the deceased driver for damages, interest, and costs, if appropriate, a trial by jury of all issues so triable and any other further relief that the Court deems just and proper in accordance with the law, Dated this ‘ { day of June 2024. Gregory S. Hagopian, Esq FBN: 980481 Gallagher & Hagopian, PI. 7341 North Tamiami Trail Sarasota, FL 34243 (941) 280-4878 (941) 727-6933 fax gh@hurtbyaccident.com Counsel for Plaintiff "2024CA000897AX" 199813837 Filed at Manatee County Clerk 06/04/2024 03:01:36 PM EDT