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Filing # 127110536 E-Filed 05/19/2021 12:13:16 PM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 50-2020-CA-007500-XXXXMB (AK)
MARIA ALICIA GUZMAN,
Plaintiff,
vs.
ANDREA D’ADDARIO AS CURATOR
OF THE ESTATE OF EDWARD JOSEPH PARADISE,
Defendant.
/
AMENDED COMPLAINT
COMES NOW the Plaintiff, MARIA ALICIA GUZMAN, by and through her undersigned
counsel and sues Defendant, ANDREA D’ADDARIO AS CURATOR OF THE ESTATE OF
EDWARD JOSEPH PARADISE, for damages and alleges as follows:
GENERAL ALLEGATIONS
1. This is an action for damages, which exceeds the sum of Thirty Thousand
($30,000.00) Dollars, excluding interest, costs and attorney's fees.
2. At all times material hereto, Plaintiff, MARIA ALICIA GUZMAN, was and is a
resident of Palm Beach County, Florida, and is otherwise, sui juris.
3. At all times material hereto, EDWARD JOSEPH PARADISE, deceased, was a
resident of Palm Beach County, Florida and died on January 14, 2019.
4. On May 13, 2021, ANDREA D’ADDARIO, Esq., was appointed as the Curator of the
Estate of Edward Joseph Paradise, deceased, and Letters of Curatorship were issued on May 13,
2021. The Order appointing Ms. D'Addario as Curator is attached hereto as Exhibit “A”. The
a
CHEN. DAIAARCACUAAIINTY Cl INeCEDU ARDIIV7ZA FLED AEMaINNAN 19.42.42 DM
Pty. PAL DLA VUUINE TT, PL, vUOL II mDnueey, ULLIAN, Yorioeue! 12.10.10 ritLetters of Curatorship are attached hereto as Exhibit “B”.
3. The Letters of Curatorship declare that Andrea D’ Addario is duly qualified under the
law of the State of Florida to perform and act as the Curator of the Estate of EDWARD JOSEPH
PARADISE under §733.50, Florida Statutes, with full power to perform any duty or function of a
personal representative, including the authority to prosecute and defend and settle and resolve the
pending lawsuit of MARIA ALICIA GUZMAN v. EDWARD JOSEPH PARADISE, now pending in
The Circuit Court of the 15th Judicial Circuit in and for Palm Beach County, Florida, Case No.: 50-
2020-CA-007500-XXXX-MB.
6. On October 21, 2020 and again on April 9, 2021, the Court granted the Plaintiff
permission to substitute The Estate of Edward Joseph Paradise or the appropriate representative of
the Estate of Edward Joseph Paradise for the deceased Defendant EDWARD JOSEPH PARADISE.
The aforementioned Orders are attached hereto collectively as Exhibit “C”.
7. At all times material hereto the Plaintiff, MARIA ALICIA GUZMAN, was the
operator of a 2016 Toyota Camry, motor vehicle, Florida License Plate No.: GNPI88 on I-95
northbound near the Belvedere Road exit, in the city of West Palm Beach, Palm Beach County,
Florida.
8. Atall times material hereto the decedent, EDWARD JOSEPH PARADISE, owned,
operated, maintained, and controlled, a 2001 Ford Explorer motor vehicle, Florida License Plate No.:
Y81HDE on I-95 northbound near the Belvedere Road exit, in the city of West Palm Beach, Palm
Beach County, Florida.
9. On December 7, 2017, Plaintiff, MARIA ALICIA GUZMAN, was the operator of the
aforementioned 2016 Toyota Camry motor vehicle on I-95 northbound near the Belvedere Road exit,
in the citv of West Palm Reach, Palm Reach County Florida when she was neoligently struck hy the
22001 Ford Explorer, owned and negligently operated by the decedent, EDWARD JOSEPH
PARADISE.
COUNT I- NEGLIGENCE AGAINST THE
THE DECEDENT EDWARD JOSEPH PARADISE
10. Plaintiff, MARIA ALICIA GUZMAN, realleges, adopts and incorporates by reference
paragraphs | through 9 as if fully set forth herein and further alleges the following:
ll. At the time of this incident, which occurred on December 7, 2017, the Decedent
EDWARD JOSEPH PARADISE, owed a duty to Plaintiff, MARIA ALICIA GUZMAN, to operate
the vehicle he was driving in a careful and safe manner and to take reasonable steps to prevent the
vehicle from causing injuries to the Plaintiff, MARIA ALICIA GUZMAN.
12. The Decedent, EDWARD JOSEPH PARADISE, breached his duty of reasonable care
and was negligent by:
a. failing to keep a proper lookout,
b. failing to safely operate his vehicle,
c. failing to take reasonable steps to prevent this crash,
d. failing to see what is there to be seen, and
e. operating his vehicle in a negligent and careless manner.
13. As a direct and proximate result of Decedent, EDWARD JOSEPH PARADISE’s,
negligence, the Plaintiff, MARIA ALICIA GUZMAN, suffered bodily injury and resulting pain and
suffering, disability, disfigurement, mental anguish. significant and nermanent scarring. loss of the
capacity for enjoyment of life, expenses of hospitalization, medical and nursing care and treatment,
and aggravation of a previously existing condition. All of these losses are either permanent or
continuing in nature and the Plaintiff will continue to suffer these losses into the future.WHEREFORE, the Plaintiff, MARIA ALICIA GUZMAN, demands judgment against
Defendant, ANDREA D’ADDARIO AS CURATOR OF THE ESTATE OF EDWARD JOSEPH
PARADISE, for damages which are in excess of the sum of THIRTY THOUSAND and 00/100
($30,000.00) DOLLARS, exclusive of costs, interest and attorney’s fees, and further demands trial by
jury.
Respectfully submitted on this 19" day of May 2021, by:
CARLOS J. JIMENEZ, P.L.
Attorney for Plaintiff
1880 North Congress Avenue, Suite 315
Boynton Beach, Fl. 33426
(Tel: 561.253-0434; Fax: 561.253.0435)
eService@247injuryLaw.com
Elactronically Signed
Feat
CARLOS J. JIMENEZ, ESQUIRE
Florida Rar No: 0636746
SCOTT GOLDSTEIN, ESQUIRE
Florida Bar No.: 0540951IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 50-2021-CP-002228XXXXSB
DIVISION: IY
IN RE:
ESTATE OF
EDWARD JOSEPH PARADISE.
Cy
OADNED ADDAINTING CHIDATAD
MAW LV UNIV BURA LU
THIS CAUSE came to be heard upon the motion of Petitioner SCOTT GOLDSTEIN for
administration of this estate with the appointment of a Curator under £.S. 733.501, and the
Court being fully advised in the premises,
ITIC ADNEDEN AAT ANTINCEN that.
1110 URULAGY AWW ALJUVULY Ula.
1. The Court appoints ANDREA D’ADDARIO as the Curator of this estate under FS.
733.501.
2. Upon posting a bond of (waived), letters of curatorship shall be issued.
3. The Curator shall have power to prosecute and defend and settle and resolve the
pending lawsuit styled GUZMAN, MARIA ALICIA versus PARADISE, EDWARD JOSEPH, now
pending in this circuit in case #50-2020-CA-007500-XXXX-MB.
he bbe
seem feore Sorc SE rae
502021CP002228XXXXSB 05/13/2021
James L. Martz
Circuit Judge
Copies to:
Edward A. Shipe, Esq., Scott Goldstein, Esq, Andrea D'Addario, Esq.
EXHIBIT "A"IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 50-2021-CP-002228XXXXSB
DIVISION: IY
IN RE:
ESTATE OF
EDWARD JOSEPH PARADISE.
Cy
TETTEDC NE CHIDATOADCHID
3 Le GUIALL UINDALLL
WHEREAS, EDWARD JOSEPH PARADISE, residing in Palm Beach County, Florida, died on
January 14, 2019;
AND WHEREAS, ANDREA D’ADDARIO has been appointed by the Court as Curator of the Estate
of EDWARD JOSEPH PARADISE and has performed all acts requisite to issuance of Letters of
Curatorship in the Estate,
NOW, Therefore, I, the undersigned Circuit Court Judge, declare ANDREA D'ADDARIO to be duly
qualified under the law of the State of Florida to perform and act as the Curator of the Estate of
EDWARD JOSEPH PARADISE under §733.501, Florida Statutes, with full power to perform any duty
or function of a personal representative, including the authority to prosecute and defend and settle
and resolve the pending lawsuit styled GUZMAN, MARIA ALICIA versus PARADISE, EDWARD JOSEPH,
now pending in this circuit in case #50-2020-CA-007500-XXXX-MB.
Lo are James Carta cireult Judge
502021CP002228XXXXSB 05/13/2021
James L. Martz
Circuit Judge
Edward A. Shipe, Esq., Scott Goldstein, Esq, Andrea D'Addario, Esq.
EXHIBIT "B"IN THE CIRCUIT COURT OF THE
1STH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.2020-CA-7500
MARIA ALICIA GUZMAN,
Plaintiff,
vs.
EDWARD JOSEPH PARADISE,
Defendant.
JOSEPH PA DISE WHO IS Now DECEASED
THIS CAUSE having come to be heard on the Plaintiff, MARIA ALICIA GUZMAN’s,
Motion To Substitute The Estate of Edward Joseph Paradise for the Individually Named
Defendant, Edward Joseph Paradise, who is now deceased and the Court being otherwise fully
advised in the premises after a hearing held on October 21, 2020, it is hereby;
ORDERED AND ADJUDGED, that:
The Motion is GRANTED. The Estate of Edward Joseph Paradise, Deceased, or the
appropriate representative of the Estate for Defendant, Edward Joseph Paradise, shall be
substituted as the named Defendant in this case. Plaintiff shall have 120 days from the date of
this order to formally substitute and serve The Estate of Edward Joseph Paradise, Deceased, or
the appropriate representative of the Estate for Defendant, Edward Joseph Paradise.
DONE AND ORDERED, in Chambers at West Palm Beach, Palm Beach County, Florida,
this 215 day of October, 2020.
seas chopra a opi
me L Martz 7ZJudge
”
50-2020-CA-007500-XXXX-MB — 10/21/2020
James L. Martz
Judge
Copies furnished to:
Scott Goldstein, Esq., Law Offices of Carlos Jimenez, PL, 1880 North Congress Avenue, Suite
315, Boynton Beach, FL 33426, eservice@24 7injurylaw.com
Joseph Maryuma Esq., at Ftlauderdalelegal@allstate.com
EXHIBIT "C"
Page 1of2Case No. 50-2020-CA-007500-XXXX-MB
Page 2 of 2IN THE CIRCUIT COURT OF THE
1STH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.2020-CA-7500
MARIA ALICIA GUZMAN,
Plaintiff,
vs.
EDWARD JOSEPH PARADISE,
Defendant.
NAMED DEFENDANT, EDWARD JOSEPH PARADISE WHO IS NOW DECEASED
THIS CAUSE having come to be heard on the Plaintiff, MARIA ALICIA GUZMAN’s,
Motion for Extension of Time to Substitute The Estate of Edward Joseph Paradise for the
Individually Named Defendant, Edward Joseph Paradise, who is now deceased and the Court
being otherwise fully advised in the premises after a hearing held on April 8, 2021, it is hereby;
ORDERED AND ADJUDGED, that:
The Motion is GRANTED. The Estate of Edward Joseph Paradise, Deceased, or the
appropriate representative of the Estate for Defendant, Edward Joseph Paradise, shall be
substituted as the named Defendant in this case. Plaintiff shall have 45 days from the date of this
order to formally substitute and serve The Estate of Edward Joseph Paradise, Deceased, or the
appropriate representative of the Estate for Defendant, Edward Joseph Paradise.
DONE AND ORDERED, in Chambers at West Paim Beach, Palm Beach County, Florida,
FS,
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Soy ee CUT
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Fa tas
aige Giilman_, Circuit Judge
Apminisrratte oreNf: of Tue Courr
50-2020-CA-007500-XXXX-MB 04/09/2021
Paige Gillman
Circuit Judge
Copies furnished to:
Page 1of2Case No. 50-2020-CA-007500-XXXX-MB
Scott Goldstein, Esq., Law Offices of Carlos Jimenez, PL, 1880 North Congress Avenue, Suite
315, Boynton Beach, FL 33426, eservice@24 7injurylaw.com
Joseph Maryuma Esq, at Ftlauderdalelegal@allstate.com
Page 2 of 2