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Case Number: CACE-19-022586 Division: 09
Filing # 98191205 E-Filed 10/31/2019 02:45:12 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.:
ARIELLE ABRAMOVITZ,
Plaintiff,
vs.
EARL SAWISCH,
Defendant.
/
COMPLAINT
Plaintiff, ARIELLE ABRAMOVITZ, (“Plaintiff”), by and through his undersigned
counsel, hereby sues Defendant, EARL SAWISCH, (“Defendant”), and states as follows:
THE PARTIES
1. At all times herein mentioned, Plaintiff was and is a resident of Palm Beach
County, Florida.
2. Upon information and belief, at all times material hereto, Defendant was and is a
resident of Broward County, Florida.
JURISDICTION AND VENUE
3. Plaintiff re-alleges and incorporates by reference the allegations of paragraphs 1
through 2, inclusive, as though set forth at length herein again.
4. This Court has subject matter jurisdiction over this lawsuit in that it seeks money
damages in excess of $15,000.00, exclusive of costs and interest.
Page 1 of 3
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/31/2019 02:45:10 PM.****5. This Court has personal jurisdiction over the parties because Defendant resides in
the State of Florida.
6. Venue is proper in this Court because the subject accident and Plaintiff's damages
occurred in Broward County, Florida.
GENERAL ALLEGATIONS
7. Plaintiff re-alleges and incorporates by reference the allegations of paragraphs 1
through 6, inclusive, as though set forth at length herein again.
8. On December 28, 2018, Plaintiff was the owner and driver of a 2015 Toyota.
9. On said date, Defendant was the owner and driver of a 2018 GMC.
10. Onsaid date, at or near the intersection of SE 13" Court and S. Federal Highway,
Defendant negligently rear-ended Plaintiff's vehicle.
COUNT I: NEGLIGENCE
lL. Plaintiff re-alleges and incorporates by reference the allegations of paragraphs 1
through 10, inclusive, as though set forth at length herein again.
12. Onsaid date and at said place, Defendant owed Plaintiff and others similarly
situated a duty of care to operate his vehicle in a safe and competent manner.
13. On said date and at said place, Defendant breached that duty by rear-ending
Plaintiff's vehicle.
14. Asa direct and proximate result of Defendant’s negligence, Plaintiff suffered
bodily injuries and resulting pain and suffering, disability, disfigurement, mental anguish,
inconvenience, loss of capacity for the enjoyment of life, aggravation of any applicable
preexisting condition, medical expenses, expense of hospitalization, and medical and nursing
Page 2 of 3treatment. The losses are permanent and continuing and Plaintiff will suffer the losses in the
future.
15. Asa further direct and proximate result of the negligence of Defendant, Plaintiff
sustained personal injuries which have impaired her ability to work and to continue her daily
activities. As a direct and proximate result of Defendant’s negligence, Plaintiff lost earnings and
future earning capacity in an amount to be proven at the time of trial.
WHEREFORE, Plaintiff, ARIELLE ABRAMOVITZ, prays for judgment against
Defendant, EARL SAWISCH, for general and special damages in an amount to be determined at
the trial in this matter, costs, and any other relief that this Court deems just and proper.
Plaintiff, ARIELLE ABRAMOVITZ, hereby demands a trial by jury in this action.
Dated: October 31, 2019 Law Offices of Marshall E. Rosenbach
Attorney for Plaintiff, ARIELLE ABRAMOVITZ
11430 U.S. Highway 1
North Palm Beach, Florida 33408
(561) 627-8990 Telephone
(561) 694-1359 Facsimile
/s/ Marshall E. Rosenbach
Marshall E. Rosenbach, Esq.
Florida Bar No. 698032
E-mail 1: marshall@marshallrosenbach.com
E-mail 2: service@marshallrosenbach.com
Page 3 of 3
Preview
Case Number: CACE-19-022586 Division: 09 Filing # 98191205 E-Filed 10/31/2019 02:45:12 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: ARIELLE ABRAMOVITZ, Plaintiff, vs. EARL SAWISCH, Defendant. / COMPLAINT Plaintiff, ARIELLE ABRAMOVITZ, (“Plaintiff”), by and through his undersigned counsel, hereby sues Defendant, EARL SAWISCH, (“Defendant”), and states as follows: THE PARTIES 1. At all times herein mentioned, Plaintiff was and is a resident of Palm Beach County, Florida. 2. Upon information and belief, at all times material hereto, Defendant was and is a resident of Broward County, Florida. JURISDICTION AND VENUE 3. Plaintiff re-alleges and incorporates by reference the allegations of paragraphs 1 through 2, inclusive, as though set forth at length herein again. 4. This Court has subject matter jurisdiction over this lawsuit in that it seeks money damages in excess of $15,000.00, exclusive of costs and interest. Page 1 of 3 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/31/2019 02:45:10 PM.****5. This Court has personal jurisdiction over the parties because Defendant resides in the State of Florida. 6. Venue is proper in this Court because the subject accident and Plaintiff's damages occurred in Broward County, Florida. GENERAL ALLEGATIONS 7. Plaintiff re-alleges and incorporates by reference the allegations of paragraphs 1 through 6, inclusive, as though set forth at length herein again. 8. On December 28, 2018, Plaintiff was the owner and driver of a 2015 Toyota. 9. On said date, Defendant was the owner and driver of a 2018 GMC. 10. Onsaid date, at or near the intersection of SE 13" Court and S. Federal Highway, Defendant negligently rear-ended Plaintiff's vehicle. COUNT I: NEGLIGENCE lL. Plaintiff re-alleges and incorporates by reference the allegations of paragraphs 1 through 10, inclusive, as though set forth at length herein again. 12. Onsaid date and at said place, Defendant owed Plaintiff and others similarly situated a duty of care to operate his vehicle in a safe and competent manner. 13. On said date and at said place, Defendant breached that duty by rear-ending Plaintiff's vehicle. 14. Asa direct and proximate result of Defendant’s negligence, Plaintiff suffered bodily injuries and resulting pain and suffering, disability, disfigurement, mental anguish, inconvenience, loss of capacity for the enjoyment of life, aggravation of any applicable preexisting condition, medical expenses, expense of hospitalization, and medical and nursing Page 2 of 3treatment. The losses are permanent and continuing and Plaintiff will suffer the losses in the future. 15. Asa further direct and proximate result of the negligence of Defendant, Plaintiff sustained personal injuries which have impaired her ability to work and to continue her daily activities. As a direct and proximate result of Defendant’s negligence, Plaintiff lost earnings and future earning capacity in an amount to be proven at the time of trial. WHEREFORE, Plaintiff, ARIELLE ABRAMOVITZ, prays for judgment against Defendant, EARL SAWISCH, for general and special damages in an amount to be determined at the trial in this matter, costs, and any other relief that this Court deems just and proper. Plaintiff, ARIELLE ABRAMOVITZ, hereby demands a trial by jury in this action. Dated: October 31, 2019 Law Offices of Marshall E. Rosenbach Attorney for Plaintiff, ARIELLE ABRAMOVITZ 11430 U.S. Highway 1 North Palm Beach, Florida 33408 (561) 627-8990 Telephone (561) 694-1359 Facsimile /s/ Marshall E. Rosenbach Marshall E. Rosenbach, Esq. Florida Bar No. 698032 E-mail 1: marshall@marshallrosenbach.com E-mail 2: service@marshallrosenbach.com Page 3 of 3