On June 01, 2015 a
COMPLAINT
was filed
involving a dispute between
Geico General Insurance Company,
and
Herrera, Veronica,
for Civil
in the District Court of Hillsborough County.
Preview
IN THE CIRCUIT COURT OF HILLSBOROUGH COUNTY, FLORIDA
GEICO GENERAL INSURANCE COMPANY
a/s/o TREEMONISHA WILLIAMS,
Plaintiff,
v. CASE NO.
VERONICA HERRERA,
Defendant.
/
PROPERTY DAMAGE AND UNINSURED MOTORIST
SUBROGATION COMPLAINT
Plaintiff, GEICO GENERAL INSURANCE COMPANY a/s/o TREEMONISHA
WILLIAMS, sues Defendant, VERONICA HERRERA, and alleges as follows:
1. This is an action for damages which exceeds $15,000.00.
2. Plaintiff, GEICO GENERAL INSURANCE COMPANY , is a
corporation authorized to transact business in the State of Florida.
3. At all times material to this Complaint, TREEMONISHA
WILLIAMS was insured by Plaintiff, GEICO GENERAL INSURANCE COMPANY,
under a policy of insurance providing, among other coverages,
collision, uninsured and underinsured motorist coverage.
4, On or about October 24, 2011, Defendant, VERONICA HERRERA,
owned and operated a motor vehicle on Lakewood Drive at or near its
intersection with State Road 60 (Brandon Boulevard) in Hillsborough
County, Florida.
5. At that time and place, Defendant, VERONICA HERRERA, so
negligently and carelessly operated and/or maintained her motor
vehicle so as to cause it to collide with a motor vehicle operated by
TREEMONISHA WILLIAMS.
6. As a direct and proximate result of the Defendant's
negligence, TREEMONISHA WILLIAMS was injured in and about her body and
extremities, experienced pain and suffering, lost wages and suffered a
loss of earning capacity and incurred and will continue to incur
medical expenses; all of these injuries and damages are permanent and
continuing in nature and she will continue to suffer these losses inthe future.
7. As a result of the injuries and damages sustained by its
insured, GEICO GENERAL INSURANCE COMPANY has paid a total of
$15,000.00 in wuninsured/underinsured motorist benefits to, and on
behalf of, its insured.
8. As a further direct and proximate result of this accident,
Plaintiff was required to pay for the damages of the vehicle of its
insured, which included a $500.00 deductible paid directly by its
insured and rental expense incurred while the damaged vehicle was
being repaired.
9. Plaintiff is entitled to prejudgment interest on all
liquidated damages from the date of payment to its insured.
WHEREFORE, Plaintiff demands judgment against the Defendant in
the amount of $23,323.17 in damages, plus prejudgment interest and the
costs of bringing this action.
GrayRobirson,
Post Office Box 3
Lakeland, Florida 33802
(863) 284-2232
Florida Bar No. 261051
Attorneys for Plaintiff
4070600.1356
Document Filed Date
June 01, 2015
Case Filing Date
June 01, 2015
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IN THE CIRCUIT COURT OF HILLSBOROUGH COUNTY, FLORIDA GEICO GENERAL INSURANCE COMPANY a/s/o TREEMONISHA WILLIAMS, Plaintiff, v. CASE NO. VERONICA HERRERA, Defendant. / PROPERTY DAMAGE AND UNINSURED MOTORIST SUBROGATION COMPLAINT Plaintiff, GEICO GENERAL INSURANCE COMPANY a/s/o TREEMONISHA WILLIAMS, sues Defendant, VERONICA HERRERA, and alleges as follows: 1. This is an action for damages which exceeds $15,000.00. 2. Plaintiff, GEICO GENERAL INSURANCE COMPANY , is a corporation authorized to transact business in the State of Florida. 3. At all times material to this Complaint, TREEMONISHA WILLIAMS was insured by Plaintiff, GEICO GENERAL INSURANCE COMPANY, under a policy of insurance providing, among other coverages, collision, uninsured and underinsured motorist coverage. 4, On or about October 24, 2011, Defendant, VERONICA HERRERA, owned and operated a motor vehicle on Lakewood Drive at or near its intersection with State Road 60 (Brandon Boulevard) in Hillsborough County, Florida. 5. At that time and place, Defendant, VERONICA HERRERA, so negligently and carelessly operated and/or maintained her motor vehicle so as to cause it to collide with a motor vehicle operated by TREEMONISHA WILLIAMS. 6. As a direct and proximate result of the Defendant's negligence, TREEMONISHA WILLIAMS was injured in and about her body and extremities, experienced pain and suffering, lost wages and suffered a loss of earning capacity and incurred and will continue to incur medical expenses; all of these injuries and damages are permanent and continuing in nature and she will continue to suffer these losses inthe future. 7. As a result of the injuries and damages sustained by its insured, GEICO GENERAL INSURANCE COMPANY has paid a total of $15,000.00 in wuninsured/underinsured motorist benefits to, and on behalf of, its insured. 8. As a further direct and proximate result of this accident, Plaintiff was required to pay for the damages of the vehicle of its insured, which included a $500.00 deductible paid directly by its insured and rental expense incurred while the damaged vehicle was being repaired. 9. Plaintiff is entitled to prejudgment interest on all liquidated damages from the date of payment to its insured. WHEREFORE, Plaintiff demands judgment against the Defendant in the amount of $23,323.17 in damages, plus prejudgment interest and the costs of bringing this action. GrayRobirson, Post Office Box 3 Lakeland, Florida 33802 (863) 284-2232 Florida Bar No. 261051 Attorneys for Plaintiff 4070600.1356