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Case Number:19-000012-CI
Filing # 82663061 E-Filed 12/28/2018 04:03:57 PM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
OF THE STATE OF FLORIDA, IN AND FOR PINELLAS COUNTY
CIRCUIT CIVIL DIVISION
BALTAZAR MARTINEZ,
Plaintiff,
vs. Case No.:
ELLEN MARIE TISCHIO,
Defendant.
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COMPLAINT
COMES NOW the Plaintiff, BALTAZAR MARTINEZ, by and through his undersigned
attorney, sues the Defendant, ELLEN MARIE TISCHIO, and alleges:
1. This is an action for damages which are in excess ofFIFTEEN THOUSAND DOLLARS
($1 5,000.00), exclusive of costs and interest.
2. At all times material hereto, the Plaintiff, BALTAZAR MARTINEZ, was and is a resident
of Pinellas County, Florida.
3. At all times material hereto, the Defendant, ELLEN MARIE TISCHIO, was and is a
resident of Pinellas County, Florida.
4. On or about August 7, 2015, at approximately 1:15 p.m., at or near the intersection of
Tampa Rd. and U.S. Hwy. 19, in the city 0f Clearwater, Pinellas County, Florida, the Defendant,
ELLEN MARIE TISCHIO, negligently maintained, controlled and operated a motor vehicle so as t0
cause said automobile to collide with and against the automobile operated by the Plaintiff,
BALTAZAR MARTINEZ, causing serious bodily injuries to said Plaintiff.
5. As a direct and proximate result of the aforesaid negligence of the Defendant, ELLEN
***ELECTRONICALLY FILED 12/28/2018 04:03:55 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
MARIE TISCHIO, the Plaintiff, BALTAZAR MARTINEZ, was injured in and about his body and
extremities, 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 in nature and the Plaintiff will
suffer the losses in the future.
WHEREFORE, the Plaintiff, BALTAZAR MARTINEZ, demands judgment against the
Defendant, ELLEN MARIE TISCHIO, for an amount in excess of FIFTEEN THOUSAND
DOLLARS ($1 5,000.00), exclusive 0f costs and interest, and further demands a trial by jury.
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Eduardo R Latour
LATOUR & ASSOCIATES, P.A.
135 East Lemon Street
Tarpon Springs, Florida 34689
727/937-9577
Attorneys for Plaintiff
Fla. Bar No. 279994
edlatoumleadingsébgmail.com
Preview
Case Number:19-000012-CI Filing # 82663061 E-Filed 12/28/2018 04:03:57 PM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR PINELLAS COUNTY CIRCUIT CIVIL DIVISION BALTAZAR MARTINEZ, Plaintiff, vs. Case No.: ELLEN MARIE TISCHIO, Defendant. /, COMPLAINT COMES NOW the Plaintiff, BALTAZAR MARTINEZ, by and through his undersigned attorney, sues the Defendant, ELLEN MARIE TISCHIO, and alleges: 1. This is an action for damages which are in excess ofFIFTEEN THOUSAND DOLLARS ($1 5,000.00), exclusive of costs and interest. 2. At all times material hereto, the Plaintiff, BALTAZAR MARTINEZ, was and is a resident of Pinellas County, Florida. 3. At all times material hereto, the Defendant, ELLEN MARIE TISCHIO, was and is a resident of Pinellas County, Florida. 4. On or about August 7, 2015, at approximately 1:15 p.m., at or near the intersection of Tampa Rd. and U.S. Hwy. 19, in the city 0f Clearwater, Pinellas County, Florida, the Defendant, ELLEN MARIE TISCHIO, negligently maintained, controlled and operated a motor vehicle so as t0 cause said automobile to collide with and against the automobile operated by the Plaintiff, BALTAZAR MARTINEZ, causing serious bodily injuries to said Plaintiff. 5. As a direct and proximate result of the aforesaid negligence of the Defendant, ELLEN ***ELECTRONICALLY FILED 12/28/2018 04:03:55 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** MARIE TISCHIO, the Plaintiff, BALTAZAR MARTINEZ, was injured in and about his body and extremities, 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 in nature and the Plaintiff will suffer the losses in the future. WHEREFORE, the Plaintiff, BALTAZAR MARTINEZ, demands judgment against the Defendant, ELLEN MARIE TISCHIO, for an amount in excess of FIFTEEN THOUSAND DOLLARS ($1 5,000.00), exclusive 0f costs and interest, and further demands a trial by jury. ///ggw/ Eduardo R Latour LATOUR & ASSOCIATES, P.A. 135 East Lemon Street Tarpon Springs, Florida 34689 727/937-9577 Attorneys for Plaintiff Fla. Bar No. 279994 edlatoumleadingsébgmail.com