On March 31, 2017 a
Complaint,Petition
was filed
involving a dispute between
and
for AUTO NEGLIGENCE
in the District Court of Citrus County.
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Filing # 54468081 E-Filed 03/31/2017 10:02:41 AM
IN THE CIRCUIT COURT OF THE 5TH
JUDICIAL CIRCUIT IN AND FOR
CITRUS COUNTY, FLORIDA
MEGAN ALEXANDER,
Plaintiff,
vs. Case No: 2017 CA 000276 A
ASHLEY MAE KAVANAUGH,
Defendant.
/
COMPLAINT
Plaintiff, MEGAN ALEXANDER, sues Defendant, ASHLEY MAE KAVANAUGH,
stating:
1 This is a cause of action for damages in excess of $15,000.00.
2 All conditions precedent to filing this action have been complied with,
expired, and/or waived.
3 On or about May 18, 2016, Defendant, ASHLEY MAE KAVANAUGH,
owned and operated a motor vehicle on West Homosassa Trail in Citrus County,
Florida.
4 At that time and place, Defendant, ASHLEY MAE KAVANAUGH,
negligently operated or maintained the motor vehicle so that it collided with Plaintiff's
motor vehicle.
5. As the direct and proximate result of the negligence of Defendant,
ASHLEY MAE KAVANAUGH, Plaintiff, MEGAN ALEXANDER, suffered bodily injury
and resulting pain and suffering, disability, disfigurement, mental anguish, loss of
capacity for the enjoyment of life, expense of hospitalization, medical and nursing care
and treatment, loss of earnings, loss of ability to earn money, and aggravation of a
previously existing condition. The losses are either permanent or continuing and Plaintiff
will suffer the losses in the future.
6 Plaintiffs automobile was damaged and Plaintiff lost use of it during the
period required for its repair or replacement.
WHEREFORE, Plaintiff, MEGAN ALEXANDER, demands judgment for damages
against Defendant, ASHLEY MAE KAVANAUGH.
Plaintiff demands trial by jury on all issues so triable.
Respectfully, submitted this 31st day of March, 2017.
By:_s/ Michael C. Peckham
MICHAEL C. PECKHAM
Attorney Email: MPeckham@schwedlawfirm.com
Eservice Email: eservice@schwediawfirm.com
Bar Number: 77564
Attorneys for Plaintiff
Schwed, Adams, Sobel, & McGinley, P.A.
7111 Fairway Drive, Suite 105
Palm Beach Gardens, Florida 33418
Telephone: (561) 694-6079
Facsimile: (561) 694-6089
Document Filed Date
March 31, 2017
Case Filing Date
March 31, 2017
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Filing # 54468081 E-Filed 03/31/2017 10:02:41 AM IN THE CIRCUIT COURT OF THE 5TH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA MEGAN ALEXANDER, Plaintiff, vs. Case No: 2017 CA 000276 A ASHLEY MAE KAVANAUGH, Defendant. / COMPLAINT Plaintiff, MEGAN ALEXANDER, sues Defendant, ASHLEY MAE KAVANAUGH, stating: 1 This is a cause of action for damages in excess of $15,000.00. 2 All conditions precedent to filing this action have been complied with, expired, and/or waived. 3 On or about May 18, 2016, Defendant, ASHLEY MAE KAVANAUGH, owned and operated a motor vehicle on West Homosassa Trail in Citrus County, Florida. 4 At that time and place, Defendant, ASHLEY MAE KAVANAUGH, negligently operated or maintained the motor vehicle so that it collided with Plaintiff's motor vehicle. 5. As the direct and proximate result of the negligence of Defendant, ASHLEY MAE KAVANAUGH, Plaintiff, MEGAN ALEXANDER, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money, and aggravation of a previously existing condition. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. 6 Plaintiffs automobile was damaged and Plaintiff lost use of it during the period required for its repair or replacement. WHEREFORE, Plaintiff, MEGAN ALEXANDER, demands judgment for damages against Defendant, ASHLEY MAE KAVANAUGH. Plaintiff demands trial by jury on all issues so triable. Respectfully, submitted this 31st day of March, 2017. By:_s/ Michael C. Peckham MICHAEL C. PECKHAM Attorney Email: MPeckham@schwedlawfirm.com Eservice Email: eservice@schwediawfirm.com Bar Number: 77564 Attorneys for Plaintiff Schwed, Adams, Sobel, & McGinley, P.A. 7111 Fairway Drive, Suite 105 Palm Beach Gardens, Florida 33418 Telephone: (561) 694-6079 Facsimile: (561) 694-6089