On June 16, 2017 a
Complaint,Petition
was filed
involving a dispute between
Geico General Insurance Company,
and
Romero, Ronny,
Umanzor Romero, Ronny Omar,
for Auto Negligence
in the District Court of Miami-Dade County.
Preview
Filing # 57845406 E-Filed 06/16/2017 08:51:56 AM
IN THE CIRCUIT COURT FOR THE 11TH
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
GEICO GENERAL INSURANCE COMPANY
as subrogee of WALID JABER
Plaintiff, CASE NO.:
-Vs-
RONNY OMAR UMANZOR ROMERO
a/k/a RONNY ROMERO,
Defendant.
=f
COMPLAINT
Plaintiff, GEICO GENERAL INSURANCE COMPANY as subrogee of WALID JABER sues Defendant,
RONNY OMAR UMANZOR ROMERO a/k/a RONNY ROMERO, for $40,536.38 as Damages, and would allege:
L.
2.
3.
10.
1,
This is an action for damages greater than $15,000.00.
At all times material hereto, WALID JABER was insured by Plaintiff a corporation duly
licensed to transact the business of insurance in and about the State of Florida.
Defendant is a resident of the State of Florida, or alternatively, Defendant is concealing
themselves within the State of Florida or is a non-resident of the State of Florida who
accepted the privilege extended by Florida law to nonresidents of operating a motor vehicle or
of having it operated, or permitting any motor vehicle owned or leased or controlled by the
Defendant to be operated within Florida and by operation of the motor vehicle in person
thereby constituted the Secretary of State of Florida as the Defendant's agent for the service of
process in a civil action in Florida arising out of or by reason of any accident or collision
occurring within Florida in which the motor vehicle is involved according to Florida Statute
ss 48.171.
On or about JANUARY 11, 2015, Defendant owned and operated a motor vehicle.
On or about JANUARY 11, 2015, Defendant operated the vehicle in such a negligent and
careless manner that a collision occurred in MIAMI-DADE County, Florida causing property
damage to the Plaintiff insured's vehicle.
Defendant owed the insured a duty of care while operating the motor vehicle.
Defendant breached said duty of care by causing the subject motor vehicle accident.
At said time and place, there was a policy of insurance issued by Plaintiff which covered the
aforementioned damages.
Pursuant to said policy of insurance, Plaintiff paid to or on behalf of the insured the sum of
$40,536.38 in damages for repairs to its insured's vehicle and deductible and Plaintiff is
entitled to subrogation.
Defendant owes Plaintiff $40,536.38
All conditions precedent to this action have occurred, been met or been waived.
WHEREFORE, Plaintiff demands Judgment against Defendant, RONNY OMAR UMANZOR
ROMERO a/k/a RONNY ROMERO, for $40,536.38 in damages, plus interest and costs.
YS29067
LAW OFFICE OF YATES & SCHILLER, P.A.
7900 Glades Road, Suite 405
Boca Raton, Florida 33434
Designated email address for pleadings only:
pleadings@yatesandschiller.com
Phone: 561-477-7729
Fax: 561-477-7731
By: s/ Bruce H. Schiller, Esq.
BRUCE H. SCHILLER, Esq.
FBN: 982725
Document Filed Date
June 16, 2017
Case Filing Date
June 16, 2017
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Filing # 57845406 E-Filed 06/16/2017 08:51:56 AM IN THE CIRCUIT COURT FOR THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GEICO GENERAL INSURANCE COMPANY as subrogee of WALID JABER Plaintiff, CASE NO.: -Vs- RONNY OMAR UMANZOR ROMERO a/k/a RONNY ROMERO, Defendant. =f COMPLAINT Plaintiff, GEICO GENERAL INSURANCE COMPANY as subrogee of WALID JABER sues Defendant, RONNY OMAR UMANZOR ROMERO a/k/a RONNY ROMERO, for $40,536.38 as Damages, and would allege: L. 2. 3. 10. 1, This is an action for damages greater than $15,000.00. At all times material hereto, WALID JABER was insured by Plaintiff a corporation duly licensed to transact the business of insurance in and about the State of Florida. Defendant is a resident of the State of Florida, or alternatively, Defendant is concealing themselves within the State of Florida or is a non-resident of the State of Florida who accepted the privilege extended by Florida law to nonresidents of operating a motor vehicle or of having it operated, or permitting any motor vehicle owned or leased or controlled by the Defendant to be operated within Florida and by operation of the motor vehicle in person thereby constituted the Secretary of State of Florida as the Defendant's agent for the service of process in a civil action in Florida arising out of or by reason of any accident or collision occurring within Florida in which the motor vehicle is involved according to Florida Statute ss 48.171. On or about JANUARY 11, 2015, Defendant owned and operated a motor vehicle. On or about JANUARY 11, 2015, Defendant operated the vehicle in such a negligent and careless manner that a collision occurred in MIAMI-DADE County, Florida causing property damage to the Plaintiff insured's vehicle. Defendant owed the insured a duty of care while operating the motor vehicle. Defendant breached said duty of care by causing the subject motor vehicle accident. At said time and place, there was a policy of insurance issued by Plaintiff which covered the aforementioned damages. Pursuant to said policy of insurance, Plaintiff paid to or on behalf of the insured the sum of $40,536.38 in damages for repairs to its insured's vehicle and deductible and Plaintiff is entitled to subrogation. Defendant owes Plaintiff $40,536.38 All conditions precedent to this action have occurred, been met or been waived. WHEREFORE, Plaintiff demands Judgment against Defendant, RONNY OMAR UMANZOR ROMERO a/k/a RONNY ROMERO, for $40,536.38 in damages, plus interest and costs. YS29067 LAW OFFICE OF YATES & SCHILLER, P.A. 7900 Glades Road, Suite 405 Boca Raton, Florida 33434 Designated email address for pleadings only: pleadings@yatesandschiller.com Phone: 561-477-7729 Fax: 561-477-7731 By: s/ Bruce H. Schiller, Esq. BRUCE H. SCHILLER, Esq. FBN: 982725