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Filing # 119790600 E-Filed 01/18/2021 05:18:39 PM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT,
IN AND FOR FLAGLER COUNTY, FLORIDA
MICHAEL RUDY, CASE NO.: 2021 CA 000024
Plaintiff,
v.
THE STANDARD FIRE
INSURANCE COMPANY,
Defendant.
/
COMPLAINT
COMES NOW the Plaintiff, MICHAEL RUDY, by and through his undersigned
attorney, sues the Defendant, THE STANDARD FIRE INSURANCE COMPANY, and alleges
the following:
1. This is an action for damages in excess of $30,000.00.
2. At all times material hereto, the Plaintiff, MICHAEL RUDY, was a resident of
Flagler Beach, Flagler County, Florida.
3. At all times material hereto, the Defendant, THE STANDARD FIRE
INSURANCE COMPANY, was a foreign profit corporation licensed in the State of Florida and
conducting business in Flagler County, Florida.
4. Venue is proper with this Court because the incident giving rise to this cause of
action occurred in Palm Coast, Flagler County, Florida.
5. On or about February 29, 2016, Leonard J. Tadeo was the registered owner of a
2001 Ford Ranger with vehicle identification number 1FTYR14E81TA83018 and Florida license
tag number 2648TJ.
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 01/19/2021 09:44 AM6. On or about February 29, 2016, Leonard J. Tadeo carried inadequate or no
liability insurance on the 2001 Ford Ranger with vehicle identification number
1FTYR14E81TA83018 and Florida license tag number 2648TJ.
7. On or about February 29, 2016, at approximately 3:11 p.m., Leonard J. Tadeo
operated said 2001 Ford Ranger with vehicle identification number 1FTYR14E81TA83018 and
Florida license tag number 2648TJ on N. Old Kings Road at or near the intersection of State
Road 100 in Palm Coast, Flagler County, Florida.
8. At said time and location, Leonard J. Tadeo negligently operated or maintained
said 2001 Ford Ranger with vehicle identification number 1FTYR14E81TA83018 and Florida
license tag number 2648TJ when he caused the 2001 Ford Ranger to collide into a 2008 Toyota
Tacoma with vehicle identification number 5STEUU42N68Z506711 and Florida license tag
number EUJL22 that was being driven by the seat belted Plaintiff, MICHAEL RUDY.
9. As a direct and proximate result of the aforementioned negligence, the Plaintiff,
MICHAEL RUDY, suffered bodily injuries and resulting pain and suffering, disability, mental
anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical care, and
treatment. The losses are either permanent or continuing and the Plaintiff, MICHAEL RUDY,
will suffer such losses in the future.
10. At all times material hereto, the Defendant, THE STANDARD FIRE
INSURANCE COMPANY, issued an automobile insurance policy to the Plaintiff, MICHAEL
RUDY, identified as policy number §§, which included Uninsured/Underinsured
Motorist coverage, by the terms of which the Defendant, THE STANDARD FIRE INSURANCE
COMPANY, agreed to pay all damages which the Plaintiff, MICHAEL RUDY, should be
legally entitled to recover from the owner or operator of an uninsured or underinsured motor
vehicle.11. That Defendant, THE STANDARD FIRE INSURANCE COMPANY, has
exclusive possession of the original of said automobile insurance policy or true and correct
copies thereof.
12. That on or about February 29, 2016, the Plaintiff, MICHAEL RUDY, suffered
bodily injuries and related damages as a result of the negligent operation of an uninsured or
underinsured motor vehicle.
13. That Defendant, THE STANDARD FIRE INSURANCE COMPANY, has failed
and refused to pay the Plaintiff, MICHAEL RUDY, the sums due and owing the Plaintiff,
MICHAEL RUDY, for bodily injuries and related damages arising out of the negligent operation
of said uninsured or underinsured motor vehicle.
WHEREFORE, the Plaintiff, MICHAEL RUDY, demands judgment for damages against
the Defendant, THE STANDARD FIRE INSURANCE COMPANY, and demands a trial by jury
on all issues.
CHANFRAU & CHANFRAU
/s/ Greg Olsen
Dated: January 18, 2021 William M. Chanfrau, Jr., Esq.
FL Bar No. 0115339
Gregory A. Olsen, Esq.
FL Bar No. 1025866
701 N. Peninsula Drive
Daytona Beach, FL 32118
P: 386-258-7313 F: 386-238-1464
Attorneys for Plaintiff
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Filing # 119790600 E-Filed 01/18/2021 05:18:39 PM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA MICHAEL RUDY, CASE NO.: 2021 CA 000024 Plaintiff, v. THE STANDARD FIRE INSURANCE COMPANY, Defendant. / COMPLAINT COMES NOW the Plaintiff, MICHAEL RUDY, by and through his undersigned attorney, sues the Defendant, THE STANDARD FIRE INSURANCE COMPANY, and alleges the following: 1. This is an action for damages in excess of $30,000.00. 2. At all times material hereto, the Plaintiff, MICHAEL RUDY, was a resident of Flagler Beach, Flagler County, Florida. 3. At all times material hereto, the Defendant, THE STANDARD FIRE INSURANCE COMPANY, was a foreign profit corporation licensed in the State of Florida and conducting business in Flagler County, Florida. 4. Venue is proper with this Court because the incident giving rise to this cause of action occurred in Palm Coast, Flagler County, Florida. 5. On or about February 29, 2016, Leonard J. Tadeo was the registered owner of a 2001 Ford Ranger with vehicle identification number 1FTYR14E81TA83018 and Florida license tag number 2648TJ. Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 01/19/2021 09:44 AM6. On or about February 29, 2016, Leonard J. Tadeo carried inadequate or no liability insurance on the 2001 Ford Ranger with vehicle identification number 1FTYR14E81TA83018 and Florida license tag number 2648TJ. 7. On or about February 29, 2016, at approximately 3:11 p.m., Leonard J. Tadeo operated said 2001 Ford Ranger with vehicle identification number 1FTYR14E81TA83018 and Florida license tag number 2648TJ on N. Old Kings Road at or near the intersection of State Road 100 in Palm Coast, Flagler County, Florida. 8. At said time and location, Leonard J. Tadeo negligently operated or maintained said 2001 Ford Ranger with vehicle identification number 1FTYR14E81TA83018 and Florida license tag number 2648TJ when he caused the 2001 Ford Ranger to collide into a 2008 Toyota Tacoma with vehicle identification number 5STEUU42N68Z506711 and Florida license tag number EUJL22 that was being driven by the seat belted Plaintiff, MICHAEL RUDY. 9. As a direct and proximate result of the aforementioned negligence, the Plaintiff, MICHAEL RUDY, suffered bodily injuries and resulting pain and suffering, disability, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical care, and treatment. The losses are either permanent or continuing and the Plaintiff, MICHAEL RUDY, will suffer such losses in the future. 10. At all times material hereto, the Defendant, THE STANDARD FIRE INSURANCE COMPANY, issued an automobile insurance policy to the Plaintiff, MICHAEL RUDY, identified as policy number §§, which included Uninsured/Underinsured Motorist coverage, by the terms of which the Defendant, THE STANDARD FIRE INSURANCE COMPANY, agreed to pay all damages which the Plaintiff, MICHAEL RUDY, should be legally entitled to recover from the owner or operator of an uninsured or underinsured motor vehicle.11. That Defendant, THE STANDARD FIRE INSURANCE COMPANY, has exclusive possession of the original of said automobile insurance policy or true and correct copies thereof. 12. That on or about February 29, 2016, the Plaintiff, MICHAEL RUDY, suffered bodily injuries and related damages as a result of the negligent operation of an uninsured or underinsured motor vehicle. 13. That Defendant, THE STANDARD FIRE INSURANCE COMPANY, has failed and refused to pay the Plaintiff, MICHAEL RUDY, the sums due and owing the Plaintiff, MICHAEL RUDY, for bodily injuries and related damages arising out of the negligent operation of said uninsured or underinsured motor vehicle. WHEREFORE, the Plaintiff, MICHAEL RUDY, demands judgment for damages against the Defendant, THE STANDARD FIRE INSURANCE COMPANY, and demands a trial by jury on all issues. CHANFRAU & CHANFRAU /s/ Greg Olsen Dated: January 18, 2021 William M. Chanfrau, Jr., Esq. FL Bar No. 0115339 Gregory A. Olsen, Esq. FL Bar No. 1025866 701 N. Peninsula Drive Daytona Beach, FL 32118 P: 386-258-7313 F: 386-238-1464 Attorneys for Plaintiff