Preview
we" CASE NUMBER: 502021CA001896XXXXMB Div: AK ****
Filing # 121226136 E-Filed 02/11/2021 11:36:45 AM
19449.1
IN THE CIRCUIT COURT, OF THE
15“ JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO:
DIVISION:
MARC HARRIS and NADIA JOSEPH-HARRIS,
Plaintiff,
‘VS.
ALAN DENSEN
Defendant,
/
COMPLAINT
COMES NOW, the Plaintiffs, MARC HARRIS and NADIA JOSEPH-HARRIS, by and through
their undersigned counsel and hereby sues the Defendant, ALAN DENSEN, and alleges as follows:
GENERAL ALLEGATIONS
1 This is an action for damages in excess of Thirty Thousand Dollars ($30,000.00),
exclusive of interest, costs and attorneys’ fees.
2. That at all times material to the cause herein, the Plaintiff, MARC HARRIS, was and is a
resident of Palm Beach County, Florida.
3. That at all times material to the cause herein, the Plaintiff, NADIA JOSEPH-HARRIS,
was and is a resident of Palm Beach County, Florida.
4. That at all times material to the cause herein, the Defendant, ALAN DENSEN, was a
resident of Palm Beach County, Florida.
5. On or about November 20, 2019, ALAN DENSEN, was the owner and driver of a 2018
Volvo that was being operated on or about W Atlantic Ave in Palm Beach County, Florida.
COUNT I - NEGLIGENCE OF ALAN DENSEN AS TO MARC HARRIS
Plaintiff realleges and reavers all of the general allegations contained in Paragraphs 1 through 5
above, as though fully set forth herein.
CHEN. DAIAARCACUAAIINTY CL INCEDU ARDIIV7ZN FLED N9M141NNNA 44.9045 ANA
HILLY. PAL DLA VUUINE TT, FL, VUOL IE mDnueey, ULLIAN, ver eue! 1 .ou.ty mi6. That at above time and place, the Defendant, ALAN DENSEN, did owe a duty of care to
the Plaintiff, MARC HARRIS, to use reasonable care and/or caution to properly maintain, operate, and
control the motor vehicle he was operating.
fi That at said time and place, the Defendant, ALAN DENSEN, did breach the above-
mentioned duty by negligently and/or carelessly operating and/or maintaining said motor vehicle so as to
cause it to strike the motor vehicle in which the Plaintiff, MARC HARRIS, was driving.
8. That as a direct, proximate and foreseeable result of the negligence of the Defendant,
ALAN DENSEN, the Plaintiff, MARC HARRIS, 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 and the ability to earn money
and aggravation of a preexisting condition.
9. That the losses are either permanent or continuing in nature, and Plaintiff will suffer
losses in the future.
WHEREFORE, Plaintiff, MARC HARRIS, demands judgment plus costs and interest against the
Defendant, ALAN DENSEN, and further demands trial by jury.
COUNT Il—~NEGLIGENCE OF ALAN DENSEN AS TO NADIA JOSEPH-HARRIS
Plaintiff realleges and reavers all of the general allegations contained in Paragraphs | through 5
above, as though fully set forth herein.
10. That at above time and place, the Defendant, ALAN DENSEN, did owe a duty of care to
the Plaintiff, NADIA JOSEPH-HARRIS, to use reasonable care and/or caution to properly maintain,
operate, and control the motor vehicle he was operating.
11. That at said time and place, the Defendant, ALAN DENSEN, did breach the above-
mentioned duty by negligently and/or carelessly operating and/or maintaining said motor vehicle so as to
cause it to strike the motor vehicle the Plaintiff, NADIA JOSEPH-HARRIS, was a passenger.
197 That ac a dirant nravimate and faraceaahle racnlt af the nealinence of the Nafendant
dee aulut GS @ GUeCL pProAuuale Glu AWleseeuude Tesuut On ULC He gugenmce Cf Wie acrCnGualt,
ALAN DENSEN, the Plaintiff, NADIA JOSEPH-HARRIS, suffered bodily injury and resulting pain and
2suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of
hospitalization, medical and nursing care, and treatment, loss of earnings and the ability to earn money
and aggravation of a preexisting condition.
13. That the losses are either permanent or continuing in nature, and Plaintiff will suffer
losses in the future.
WHEREFORE, Plaintiff, NADIA JOSEPH-HARRIS, demands judgment plus costs and interest
against the Defendant, ALAN DENSEN, and further demands trial by jury.
SCHULER, HALVORSON, WEISSER,
ZOELLER & OVERBECK, P.A.
1615 Forum Place, Suite 4D
Darrictars Duildine
wallistuis DULUIE,
West Palm Beach, FL 33401
Telephone: (561) 689-8180
Attorneys for Plaintiff
By: /s/ Eric Hayden
WILLIAM D. ZOELLER
Fla. Bar No.: 155233
wzoelier@shw-iaw.com
teoffey@shw-law.com
Eric Hayden
Florida Bar No: 100923
ehayden@shw-law.com
acoates@shw-law.com
Preview
we" CASE NUMBER: 502021CA001896XXXXMB Div: AK **** Filing # 121226136 E-Filed 02/11/2021 11:36:45 AM 19449.1 IN THE CIRCUIT COURT, OF THE 15“ JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: DIVISION: MARC HARRIS and NADIA JOSEPH-HARRIS, Plaintiff, ‘VS. ALAN DENSEN Defendant, / COMPLAINT COMES NOW, the Plaintiffs, MARC HARRIS and NADIA JOSEPH-HARRIS, by and through their undersigned counsel and hereby sues the Defendant, ALAN DENSEN, and alleges as follows: GENERAL ALLEGATIONS 1 This is an action for damages in excess of Thirty Thousand Dollars ($30,000.00), exclusive of interest, costs and attorneys’ fees. 2. That at all times material to the cause herein, the Plaintiff, MARC HARRIS, was and is a resident of Palm Beach County, Florida. 3. That at all times material to the cause herein, the Plaintiff, NADIA JOSEPH-HARRIS, was and is a resident of Palm Beach County, Florida. 4. That at all times material to the cause herein, the Defendant, ALAN DENSEN, was a resident of Palm Beach County, Florida. 5. On or about November 20, 2019, ALAN DENSEN, was the owner and driver of a 2018 Volvo that was being operated on or about W Atlantic Ave in Palm Beach County, Florida. COUNT I - NEGLIGENCE OF ALAN DENSEN AS TO MARC HARRIS Plaintiff realleges and reavers all of the general allegations contained in Paragraphs 1 through 5 above, as though fully set forth herein. CHEN. DAIAARCACUAAIINTY CL INCEDU ARDIIV7ZN FLED N9M141NNNA 44.9045 ANA HILLY. PAL DLA VUUINE TT, FL, VUOL IE mDnueey, ULLIAN, ver eue! 1 .ou.ty mi6. That at above time and place, the Defendant, ALAN DENSEN, did owe a duty of care to the Plaintiff, MARC HARRIS, to use reasonable care and/or caution to properly maintain, operate, and control the motor vehicle he was operating. fi That at said time and place, the Defendant, ALAN DENSEN, did breach the above- mentioned duty by negligently and/or carelessly operating and/or maintaining said motor vehicle so as to cause it to strike the motor vehicle in which the Plaintiff, MARC HARRIS, was driving. 8. That as a direct, proximate and foreseeable result of the negligence of the Defendant, ALAN DENSEN, the Plaintiff, MARC HARRIS, 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 and the ability to earn money and aggravation of a preexisting condition. 9. That the losses are either permanent or continuing in nature, and Plaintiff will suffer losses in the future. WHEREFORE, Plaintiff, MARC HARRIS, demands judgment plus costs and interest against the Defendant, ALAN DENSEN, and further demands trial by jury. COUNT Il—~NEGLIGENCE OF ALAN DENSEN AS TO NADIA JOSEPH-HARRIS Plaintiff realleges and reavers all of the general allegations contained in Paragraphs | through 5 above, as though fully set forth herein. 10. That at above time and place, the Defendant, ALAN DENSEN, did owe a duty of care to the Plaintiff, NADIA JOSEPH-HARRIS, to use reasonable care and/or caution to properly maintain, operate, and control the motor vehicle he was operating. 11. That at said time and place, the Defendant, ALAN DENSEN, did breach the above- mentioned duty by negligently and/or carelessly operating and/or maintaining said motor vehicle so as to cause it to strike the motor vehicle the Plaintiff, NADIA JOSEPH-HARRIS, was a passenger. 197 That ac a dirant nravimate and faraceaahle racnlt af the nealinence of the Nafendant dee aulut GS @ GUeCL pProAuuale Glu AWleseeuude Tesuut On ULC He gugenmce Cf Wie acrCnGualt, ALAN DENSEN, the Plaintiff, NADIA JOSEPH-HARRIS, suffered bodily injury and resulting pain and 2suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care, and treatment, loss of earnings and the ability to earn money and aggravation of a preexisting condition. 13. That the losses are either permanent or continuing in nature, and Plaintiff will suffer losses in the future. WHEREFORE, Plaintiff, NADIA JOSEPH-HARRIS, demands judgment plus costs and interest against the Defendant, ALAN DENSEN, and further demands trial by jury. SCHULER, HALVORSON, WEISSER, ZOELLER & OVERBECK, P.A. 1615 Forum Place, Suite 4D Darrictars Duildine wallistuis DULUIE, West Palm Beach, FL 33401 Telephone: (561) 689-8180 Attorneys for Plaintiff By: /s/ Eric Hayden WILLIAM D. ZOELLER Fla. Bar No.: 155233 wzoelier@shw-iaw.com teoffey@shw-law.com Eric Hayden Florida Bar No: 100923 ehayden@shw-law.com acoates@shw-law.com