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Case Number: CACE-21-007654 Division: 14
Filing # 125012578 E-Filed 04/15/2021 03:34:55 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
JEAN JOSEPH ELIE, individually, Case No.:
Division:
Plaintiff,
vs.
JOSEPH BALSAMO, individually,
Defendant.
/
COMPLAINT
Plaintiff, JEAN JOSEPH ELIE, individually, hereby sues the Defendant, JOSEPH BALSAMO,
individually, and further alleges as follows:
GENERAL ALLEGATIONS
1. This is an action for damages in excess of Thirty Thousand Dollars ($30,000.00), exclusive
of costs and interest.
2. Plaintiff, JEAN JOSEPH ELIE, at all times material hereto was and is a resident of North
Lauderdale, Broward County, Florida.
3. Defendant, JOSEPH BALSAMO, at all times material hereto was and is a resident of
Coconut Creek, Broward County, Florida
4. The motor vehicle accident that is the subject matter of this Complaint occurred on October
28, 2020, at/on/near the intersection of Northwest 25 Avenue and West Copans Road in
Pompano Beach, Broward County, Florida.
COUNT I - NEGLIGENCE
5. Plaintiff, JEAN JOSEPH ELIE, re-avers and re-alleges each and every allegation contained
in paragraphs one (1) through four (4) above as if fully set forth herein.
6. On or about October 28, 2020, Defendant, JOSEPH BALSAMO, was the operator of a
2015 Jeep Compass bearing the Vehicle Identification Number 1C4NJCBA4FD436765
and the Florida vehicle license plate number ELWI76. Said vehicle was maintained,
entrusted, and/or in possession and control of Defendant, JOSEPH BALSAMO.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/15/2021 03:34:52 PM.****ELIE V. BALSAMO
Complaint
7. On or about October 28, 2020, Defendant, JOSEPH BALSAMO, negligently operated
and/or maintained said motor vehicle at/on/near the intersection of Northwest 25" Avenue
and West Copans Road in Pompano Beach, Broward County, Florida, so that she caused a
collision with the motor vehicle being operated by Plaintiff, JEAN JOSEPH ELIE.
8. Asaresult of the negligence of Defendant, JOSEPH BALSAMO, Plaintiff, JEAN JOSEPH
ELIE, suffered bodily injury that is permanent within a reasonable degree of medical
probability, resulting in pain and suffering, disability, disfigurement, mental anguish, loss
of earnings, loss of ability to earn money, loss of capacity for the enjoyment of life, expense
of hospitalization, medical and nursing care and treatment. These losses are either
permanent or continuing in nature and the Plaintiff will continue to suffer said losses in the
future.
WHEREFORE, Plaintiff, JEAN JOSEPH ELIE, demands judgment against Defendant, JOSEPH
BALSAMO, for damages in excess of Thirty Thousand Dollars ($30,000.00), plus costs incurred
herein and any other relief this court deems fit and proper.
DEMAND FOR TRIAL BY JURY
Plaintiff, JEAN JOSEPH ELIE, hereby demands a trial by jury of all issues so triable.
DATED this 15th day of April 2021.
MARSAD QURAISHI
FLORIDA BAR NO.: 0023790
PRIMARY: MARSAD@QBLAWGROUP.COM
SECONDARY: JONATHAN@QBLAWGROUP.COM
QURAISHI & BIRKMAN, P.L.
ATTORNEYS FOR PLAINTIFF
809 SE 8™ STREET
DEERFIELD BEACH, FL 33441
PHONE: (561) 444-8370
FAX: (561) 431-0385
Page 2 of 2
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Case Number: CACE-21-007654 Division: 14 Filing # 125012578 E-Filed 04/15/2021 03:34:55 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA JEAN JOSEPH ELIE, individually, Case No.: Division: Plaintiff, vs. JOSEPH BALSAMO, individually, Defendant. / COMPLAINT Plaintiff, JEAN JOSEPH ELIE, individually, hereby sues the Defendant, JOSEPH BALSAMO, individually, and further alleges as follows: GENERAL ALLEGATIONS 1. This is an action for damages in excess of Thirty Thousand Dollars ($30,000.00), exclusive of costs and interest. 2. Plaintiff, JEAN JOSEPH ELIE, at all times material hereto was and is a resident of North Lauderdale, Broward County, Florida. 3. Defendant, JOSEPH BALSAMO, at all times material hereto was and is a resident of Coconut Creek, Broward County, Florida 4. The motor vehicle accident that is the subject matter of this Complaint occurred on October 28, 2020, at/on/near the intersection of Northwest 25 Avenue and West Copans Road in Pompano Beach, Broward County, Florida. COUNT I - NEGLIGENCE 5. Plaintiff, JEAN JOSEPH ELIE, re-avers and re-alleges each and every allegation contained in paragraphs one (1) through four (4) above as if fully set forth herein. 6. On or about October 28, 2020, Defendant, JOSEPH BALSAMO, was the operator of a 2015 Jeep Compass bearing the Vehicle Identification Number 1C4NJCBA4FD436765 and the Florida vehicle license plate number ELWI76. Said vehicle was maintained, entrusted, and/or in possession and control of Defendant, JOSEPH BALSAMO. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/15/2021 03:34:52 PM.****ELIE V. BALSAMO Complaint 7. On or about October 28, 2020, Defendant, JOSEPH BALSAMO, negligently operated and/or maintained said motor vehicle at/on/near the intersection of Northwest 25" Avenue and West Copans Road in Pompano Beach, Broward County, Florida, so that she caused a collision with the motor vehicle being operated by Plaintiff, JEAN JOSEPH ELIE. 8. Asaresult of the negligence of Defendant, JOSEPH BALSAMO, Plaintiff, JEAN JOSEPH ELIE, suffered bodily injury that is permanent within a reasonable degree of medical probability, resulting in pain and suffering, disability, disfigurement, mental anguish, loss of earnings, loss of ability to earn money, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment. These losses are either permanent or continuing in nature and the Plaintiff will continue to suffer said losses in the future. WHEREFORE, Plaintiff, JEAN JOSEPH ELIE, demands judgment against Defendant, JOSEPH BALSAMO, for damages in excess of Thirty Thousand Dollars ($30,000.00), plus costs incurred herein and any other relief this court deems fit and proper. DEMAND FOR TRIAL BY JURY Plaintiff, JEAN JOSEPH ELIE, hereby demands a trial by jury of all issues so triable. DATED this 15th day of April 2021. MARSAD QURAISHI FLORIDA BAR NO.: 0023790 PRIMARY: MARSAD@QBLAWGROUP.COM SECONDARY: JONATHAN@QBLAWGROUP.COM QURAISHI & BIRKMAN, P.L. ATTORNEYS FOR PLAINTIFF 809 SE 8™ STREET DEERFIELD BEACH, FL 33441 PHONE: (561) 444-8370 FAX: (561) 431-0385 Page 2 of 2