Preview
Filing # 137187016 E-Filed 10/25/2021 12:44:36 PM
IN AND FOR THE CIRCUIT COURT
OF INDIAN RIVER COUNTY, FL
case NO. 31202)CAQ00732XXXXXX
JOHN GOLDEN,
Plaintiff,
Vs.
PROGRESSIVE AMERICAN INSURANCE
COMPANY,
Defendant.
/
COMPLAINT
Plaintiff, JOHN GOLDEN, sues Defendant, PROGRESSIVE AMERICAN
INSURANCE COMPANY, and alleges:
1 This is an action for damages which exceed $30,001.00, exclusive
of costs, interest and attorneys' fees.
2 Plaintiff, JOHN GOLDEN, at all times material to this action,
was a resident of Indian River County, Florida.
3 Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, at all times
material to this action, was registered to do business in the State
of Florida as an insurance company.
4 On or about, June 14, 2021, James Perry, an underinsured
motorist, negligently operated or maintained a motor vehicle so that
it wrongfully struck a vehicle in which Plaintiff, JOHN GOLDEN, was
driving at or near the intersection of Indian River Boulevard and
12*» Street in Vero Beach, Indian River County, Florida.
5 As a result of the aforementioned negligence, Plaintiff, JOHN
GOLDEN, suffered bodily injury and resulting pain and suffering,
disability, disfigurement, loss of capacity for the enjoyment of
life, expense of hospitalization, medical and nursing care and
treatment, and aggravation of a previously existing condition. The
losses are permanent and continuing, and Plaintiff will suffer the
losses in the future.
6 A policy of automobile insurance was purchased by JOHN GOLDEN,
from the Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, which
included uninsured motorist coverage. Plaintiff does not have a
copy of said policy in his possession, but Defendant insurer has
possession of said policy.
7 The policy of insurance was in full force and effect on June
14, 2021, when Plaintiff was seriously injured in the aforementioned
motor vehicle accident.
8 Plaintiff has complied with all conditions precedent to filing
suit.
WHEREFORE, Plaintiff, JOHN GOLDEN, demands judgment against
Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, for damages,
costs of this action and such other relief as this Court may deem
meet and just.
DATED this 25*8 day of October, 2021.
TUTTLE LAW, P.A.
/s/ Douglas W. Tuttle
Douglas W. Tuttle, Esquire
Florida Bar No. 0956066
dtuttle@verobeachinjurylaw.com
Dana C. Larsen, Esquire
Florida Bar No. 117807
dlarsenéverobeachinjurylaw.com
Jesse H. Larsen, Esquire
Florida Bar No. 86062
jlarsentverobeachinjurylaw.com
3617 20th Street
Vero Beach, Florida 32960
(772) 563-0032
(772) 563-2134 (FAX)
Attorneys for Plaintiff
(s)
Preview
Filing # 137187016 E-Filed 10/25/2021 12:44:36 PM IN AND FOR THE CIRCUIT COURT OF INDIAN RIVER COUNTY, FL case NO. 31202)CAQ00732XXXXXX JOHN GOLDEN, Plaintiff, Vs. PROGRESSIVE AMERICAN INSURANCE COMPANY, Defendant. / COMPLAINT Plaintiff, JOHN GOLDEN, sues Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, and alleges: 1 This is an action for damages which exceed $30,001.00, exclusive of costs, interest and attorneys' fees. 2 Plaintiff, JOHN GOLDEN, at all times material to this action, was a resident of Indian River County, Florida. 3 Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, at all times material to this action, was registered to do business in the State of Florida as an insurance company. 4 On or about, June 14, 2021, James Perry, an underinsured motorist, negligently operated or maintained a motor vehicle so that it wrongfully struck a vehicle in which Plaintiff, JOHN GOLDEN, was driving at or near the intersection of Indian River Boulevard and 12*» Street in Vero Beach, Indian River County, Florida. 5 As a result of the aforementioned negligence, Plaintiff, JOHN GOLDEN, suffered bodily injury and resulting pain and suffering, disability, disfigurement, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of a previously existing condition. The losses are permanent and continuing, and Plaintiff will suffer the losses in the future. 6 A policy of automobile insurance was purchased by JOHN GOLDEN, from the Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, which included uninsured motorist coverage. Plaintiff does not have a copy of said policy in his possession, but Defendant insurer has possession of said policy. 7 The policy of insurance was in full force and effect on June 14, 2021, when Plaintiff was seriously injured in the aforementioned motor vehicle accident. 8 Plaintiff has complied with all conditions precedent to filing suit. WHEREFORE, Plaintiff, JOHN GOLDEN, demands judgment against Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, for damages, costs of this action and such other relief as this Court may deem meet and just. DATED this 25*8 day of October, 2021. TUTTLE LAW, P.A. /s/ Douglas W. Tuttle Douglas W. Tuttle, Esquire Florida Bar No. 0956066 dtuttle@verobeachinjurylaw.com Dana C. Larsen, Esquire Florida Bar No. 117807 dlarsenéverobeachinjurylaw.com Jesse H. Larsen, Esquire Florida Bar No. 86062 jlarsentverobeachinjurylaw.com 3617 20th Street Vero Beach, Florida 32960 (772) 563-0032 (772) 563-2134 (FAX) Attorneys for Plaintiff (s)