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Filing # 93832045 E-Filed 08/07/2019 05:30:10 PM
IN THE CIRCUIT COURT, FOURTEENTH JUDICIAL CIRCUIT
OF THE STATE OF FLORIDA, IN AND FOR BAY COUNTY
JAMES ROBERT FLOWERS,
Plaintiff,
vs. CASE NO, 19002993CA
MASON JAMES NOLAN,
Defendant.
/
COMPLAINT WITH INTERROGATORIES,
REQUEST FOR PRODUCTION OF DOCUMENTS AND
REQUEST FOR ADMISSIONS ATTACHED
The Plaintiff, JAMES ROBERT FLOWERS, by and through his undersigned counsel,
sues the Defendant, MASON JAMES NOLAN, as follows:
COUNT ONE
The Plaintiff, JAMES ROBERT FLOWERS, sues the Defendant, MASON JAMES
NOLAN by this count and alleges:
1. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000.00).
2. The Plaintiff is a resident of Panama City, Bay County, Florida.
3. The Defendant, MASON JAMES NOLAN is a resident of Lynn Haven, Bay
County, Florida.
4. At all times material, the Defendant, MASON JAMES NOLAN, owed to the
public and Plaintiff, a duty to exercise reasonable care in the maintenance and operation of the
motor vehicle he was driving.
5. On or about May 13, 2016, on Florida Avenue and 16" Street West, Lynn Haven,
Florida, the Defendant, MASON JAMES NOLAN, so negligently operated a motor vehicle as to
cause it to collide with the vehicle being driven by JAMES ROBERT FLOWERS, | thereby
causing Plaintiff to sustain serious and permanent bodily injuries.6. As a result of injuries sustained by the Plaintiff, he has incurred the following
elements of damage:
a. Bodily injury and resulting pain and suffering, disability or physical
impairment, disfigurement, mental anguish, inconvenience and loss of capacity for the
enjoyment of life experienced in the past or to be experienced in the future.
b. The reasonable value or expense of medical care and treatment obtained in
the past or to be obtained in the future.
c. Any earnings lost in the past and any loss of ability to earn money in the
future.
7. Said injuries and damages to Plaintiff. JAMES ROBERT FLOWERS, are a legal
result of the negligence of Defendant, MASON JAMES NOLAN.
WHEREFORE, the Plaintiff, JAMES ROBERT FLOWERS, sues the Defendant,
MASON JAMES NOLAN, by this Count, and seeks damages and respectfully requests a jury
trial.
THOMPSON, P.A.
ash Wee
Florida Bar Number: 651052
120 Richard Jackson Bivd., Suite 200
Panama City Beach, Florida 32407
(850) 785-5555 Fx: (850) 785-0133
Attomey for Plaintiff
DESIGNATION OF E-MAIL ADDRESSES
Jay W. Manuel, of the law firm of Manuel & Thompson. P.A., pursuant to
Fla.R.Jud.Admin 2.51(b)(1)(A), hereby designates the following primary and secondary e-mail
addresses for e-mail service in the above-referenced case:
Primary e-mail address:
Secondary e-mail address
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Preview
Filing # 93832045 E-Filed 08/07/2019 05:30:10 PM IN THE CIRCUIT COURT, FOURTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR BAY COUNTY JAMES ROBERT FLOWERS, Plaintiff, vs. CASE NO, 19002993CA MASON JAMES NOLAN, Defendant. / COMPLAINT WITH INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS AND REQUEST FOR ADMISSIONS ATTACHED The Plaintiff, JAMES ROBERT FLOWERS, by and through his undersigned counsel, sues the Defendant, MASON JAMES NOLAN, as follows: COUNT ONE The Plaintiff, JAMES ROBERT FLOWERS, sues the Defendant, MASON JAMES NOLAN by this count and alleges: 1. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000.00). 2. The Plaintiff is a resident of Panama City, Bay County, Florida. 3. The Defendant, MASON JAMES NOLAN is a resident of Lynn Haven, Bay County, Florida. 4. At all times material, the Defendant, MASON JAMES NOLAN, owed to the public and Plaintiff, a duty to exercise reasonable care in the maintenance and operation of the motor vehicle he was driving. 5. On or about May 13, 2016, on Florida Avenue and 16" Street West, Lynn Haven, Florida, the Defendant, MASON JAMES NOLAN, so negligently operated a motor vehicle as to cause it to collide with the vehicle being driven by JAMES ROBERT FLOWERS, | thereby causing Plaintiff to sustain serious and permanent bodily injuries.6. As a result of injuries sustained by the Plaintiff, he has incurred the following elements of damage: a. Bodily injury and resulting pain and suffering, disability or physical impairment, disfigurement, mental anguish, inconvenience and loss of capacity for the enjoyment of life experienced in the past or to be experienced in the future. b. The reasonable value or expense of medical care and treatment obtained in the past or to be obtained in the future. c. Any earnings lost in the past and any loss of ability to earn money in the future. 7. Said injuries and damages to Plaintiff. JAMES ROBERT FLOWERS, are a legal result of the negligence of Defendant, MASON JAMES NOLAN. WHEREFORE, the Plaintiff, JAMES ROBERT FLOWERS, sues the Defendant, MASON JAMES NOLAN, by this Count, and seeks damages and respectfully requests a jury trial. THOMPSON, P.A. ash Wee Florida Bar Number: 651052 120 Richard Jackson Bivd., Suite 200 Panama City Beach, Florida 32407 (850) 785-5555 Fx: (850) 785-0133 Attomey for Plaintiff DESIGNATION OF E-MAIL ADDRESSES Jay W. Manuel, of the law firm of Manuel & Thompson. P.A., pursuant to Fla.R.Jud.Admin 2.51(b)(1)(A), hereby designates the following primary and secondary e-mail addresses for e-mail service in the above-referenced case: Primary e-mail address: Secondary e-mail address . | | : | | 1 { ; 1 i ; j | | ' ‘ i Q ' i :