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Filing # 106259472 E-Filed 04/15/2020 09:33:52 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-026009
CHANDLER JEAN BAPTISTE,
Plaintiff,
vs.
CITY OF SUNRISE and
FRANK ANTHONY OTELLO,
Defendants.
/
FIRST AMENDED COMPLAINT FOR DAMAGES
The Plaintiff, CHANDLER JEAN BAPTISTE, by and through his/her undersigned
attorney, sues the Defendants, CITY OF SUNRISE and FRANK ANTHONY OTELLO, and
alleges as follows:
1. That this is an action for damages in excess of Thirty Thousand ($30,000.00)
Dollars.
2. That at all times material hereto, the Plaintiff, CHANDLER JEAN BAPTISTE,
was a resident of BROWARD County, Florida and is otherwise sui juris.
3. That at all times material hereto, the Defendant, FRANK ANTHONY OTELLO
was a resident of BROWARD County, Florida and is otherwise sui juris.
4. That at all times material hereto, the Defendant, CITY OF SUNRISE, was a
political sub-division of the State of Florida, conducting business in Broward County, Florida.
5. At all times material hereto the Defendant, CITY OF SUNRISE, was and is a
political subdivision or agency of Broward County, Florida engaging in activity more
particularly described below. The activity is an operational level of decision making within the
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/15/2020 09:33:52 AM.*##*Defendant. Since this activity does not involve discretionary government functions, the
Defendant is not immune from tort liability. Thus, in accordance with Article X, Section 13 of
the Florida Constitution, the Defendant waives sovereign immunity from liability for tort.
6. Plaintiff has complied with the notice requirement of Fla. Stat. §768.28 (exhibits A, B
correspondence sent Certified Mail/Return Receipt Accepted.)
7. At all times material hereto, CITY OF SUNRISE, had an ownership, rental, bailment
or leasehold interest in a 2008 Ford vehicle (“the vehicle”) with Vehicle Identification number
1FMEU63868UA88650.
8. At all times material to this action and at the time of the incident complained of, the
CITY OF SUNRISE’S employee, Frank Anthony Otello, operated the subject vehicle described
in the complaint.
COUNT I —- NEGLIGENCE AGAINST FRANK ANTHONY OTELLO
Plaintiff realleges and reincorporates each and every allegation contained in Paragraphs 1
through and including 8 above as is set forth in full and further alleges:
9. That on or about 8/22/2018, Defendant, CITY OF SUNRISE, owned a motor
vehicle which was in the possession, custody and control of Defendant, FRANK ANTHONY
OTELLO.
10. That Defendant, FRANK ANTHONY OTELLO, had the implied and/or
expressed consent of CITY OF SUNRISE on or about 8/22/2018 to operate said motor vehicle
owned by CITY OF SUNRISE.
11. That on or about 8/22/2018, Defendant, FRANK ANTHONY OTELLO, operated
the motor vehicle, owned by Defendant, CITY OF SUNRISE, at or near the intersection of Royal
Palm Boulevard and Parkside Avenue in Margate, Broward County, Florida.12. That at the aforesaid time and place, Defendant, FRANK ANTHONY OTELLO,
owed Plaintiff and the general public a duty to operate the vehicle operated by FRANK
ANTHONY OTELLO in a reasonable and safe manner and FRANK ANTHONY OTELLO
breached said duty by:
a. Negligently attempting a left turn without assuring that the area was clear of traffic
and struck Plaintiff's vehicle;
b. Negligently turned turn into Plaintiff's path and struck Plaintiff's vehicle;
c. Negligently operating his vehicle in an unsafe manner and struck Plaintiff's
vehicle;
d. Negligently failing to keep a proper lookout and struck Plaintiff's vehicle;
e. Negligently failing to abide by a traffic control device and struck Plaintiffs
vehicle.
13. That as a direct and proximate result of Defendant, FRANK ANTHONY
OTELLO’s, aforesaid negligence, Plaintiff, CHANDLER JEAN BAPTISTE, 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, and Plaintiff will suffer the losses in
the future.
WHEREFORE, the Plaintiff, CHANDLER JEAN BAPTISTE, demands judgment
against the Defendant, FRANK ANTHONY OTELLO, for compensatory damages in excess of
Thirty Thousand ($30,000.00) Dollars, in addition to taxable costs. Plaintiff further demands
trial by jury on all issues so triable as of right by jury.COUNT II - NEGLIGENCE AGAINST CITY OF SUNRISE UNDER THE DOCTRINE
OF RESPONDEAT SUPERIOR
Plaintiff realleges and reincorporates each and every allegation contained in Paragraphs 1
through and including 8 above as if set forth in full, and pleads in the alternative:
14. That At all relevant times to this action, Frank Anthony Otello was an employee,
agent, servant and/or independent contractor of Defendant CITY OF SUNRISE and was acting
within the course and scope of that relationship.
15. That on or about 08/22/2018, Defendant, CITY OF SUNRISE owned a vehicle
which was in the possession, custody and control of Defendant’s employee, Frank Anthony
Otello.
16. That CITY OF SUNRISE’S employee, Frank Anthony Otello had the implied
and/or expressed consent of CITY OF SUNRISE on or about 08/22/2018 to operate said vehicle
owned by CITY OF SUNRISE.
17. That on or about 08/22/2018, Defendant CITY OF SUNRISE’S employee Frank
Anthony Otello operated the motor vehicle, owned by Defendant, CITY OF SUNRISE, at or
near the intersection of Royal Palm Boulevard and Parkside Avenue in Margate, BROWARD
County, Florida.
18. That at the aforesaid time and place, Defendant’s employee Frank Anthony Otello
owed Plaintiff and the general public a duty to operate the vehicle operated by CITY OF
SUNRISE in a reasonable and safe manner and Frank Anthony Otello breached said duty by:
a. Negligently attempting a left turn without assuring that the area was clear of traffic
and struck Plaintiff's vehicle;
b. Negligently turned turn into Plaintiff's path and struck Plaintiff's vehicle;c. Negligently operating his vehicle in an unsafe manner and struck Plaintiffs
vehicle;
d. Negligently failing to keep a proper lookout and struck Plaintiff's vehicle;
e. Negligently failing to abide by a traffic control device and struck Plaintiffs
vehicle.
19. That as a direct and proximate result of Defendant, CITY OF SUNRISE’s,
aforesaid negligence, Plaintiff, CHANDLER JEAN BAPTISTE, 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 loss of ability to earn money. The losses are either permanent or continuing, and
Plaintiff will suffer the losses in the future.
WHEREFORE, Plaintiff, CHANDLER JEAN BAPTISTE, demands judgment against
the Defendant, CITY OF SUNRISE, for compensatory damages in excess of Fifteen Thousand
($15,000.00) Dollars, in addition to taxable costs. Plaintiff further demands trial by jury on all
issues so triable as of right by jury.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded by
Electronic Mail to: E. BRUCE JOHNSON, ESQ., JOHNSON, ANSELMO, MURDOCH,
BURKE, PIPER, & HOCHMAN, P.A., Attorneys for Defendant, johnson@jambg.com, this
16+ day of Aw » 20. Ze.
MILLER LAW GROUP, P.A.
1937 East Atlantic Boulevard, Suite 204
Pompano Beach, Florida 33060
Telephone: (954)972-8011
Telefax: (954)782-3636Primary E-Mail: litigation@millerlaw.legal
/S/ MOHAMMED HAIDER
BY:
MOHAMMED HAIDER
Florida Bar No. 1003274EXHIBIT
“A”p
1937 E. Atlantic Boulevard, Suite 204 «Pompano Beach, Florida 33060
Tel. 954.972.8011 « Fax: 954.782.3636
(MILLER LAW GROUP
October 03, 2019
CERTIFIED MAIL - RETURN
RECEIPT REQUESTED
Article No.: 7015-0640-0002-0705-0474
Office of the City Attorney
ATTN: Risk Management
10770 West Oakland Park Blvd.
Sunrise, FL 33351
RE: Case Style : Chandler Jean Baptiste v. City of Sunrise
Date of Accident : August 22, 2018
Claim No. : VA2018092123
Written Notice of Tort Action Pursuant to F.S. 768.26 (6
To Whom It May Concern:
Please be advised that this firm has been retained to represent Mr. Chandler Jean Baptiste for
injuries sustained due to the negligence, errors, or omissions of your employees, agents, or
representatives at City of Sunrise, Broward County, Florida. Further, please deem this letter as
formal notice pursuant to Florida Statute Section 768.28 that Mr, Jean Baptiste is making this claim
against City of Sunrise.
On August 22", 2018, at approximately 1:37 p.m., Mr. Jean Baptiste was traveling eastbound on
Royal Palm Boulevard approaching the intersection with Parkside Avenue when your agent,
employee or servant disregarded a posted stop sign and struck Mr. Jean Baptiste’s vehicle. Mr.
Jean Baptiste suffered injuries to his face, neck, and back. He has incurred over $56,854.30 in
unpaid medical bills which was provided to Ms. Jocelyn Kiss at Florida Municipal Insurance trust
on June 27", 2019. To date, a reasonable offer of settlement has not been extended.
Pursuant to Florida Statute Section 768.28(6)(c), please be advised that Mr. Jean Baptiste was born
on 11/15/1994. Mr. Jean Baptiste’s Social Security Number is ME. Further, there are no
prior adjudicated unpaid claims in excess of $200.00 regarding this incident. Upon receipt of this
letter, please contact me so that we may discuss this claim in greater detail.
Thank you for your anticipated cooperation.Very truly yours,
Mohammed Haider, Esq.
MH:es
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BeJe MILLER LAW GROUP
1937 E. Atlantic Boulevard, Suite 204 Pompano Beach, Florida 33060
Tel. 954.972.80116 Fax: 954.782.3636
December 09, 2019
CERTIFIED MAIL - RETURN
RECEIPT REQUESTED
Article No.: 7015-0640-0002-0705-2263
Florida's Department of financial services
200 E. Gaines St.
Tallahassee, FL 32399
RE: Case Style : Chandler Jean Baptiste v. City of Sunrise
Date of Accident : August 22, 2018
Claim No. : VA2018092123
Written Notice of Tort Acti nt to 768.26
To Whom It May Concern:
Please be advised that this firm has been retained to represent Mr. Chandler Jean Baptiste for
injuries sustained due to the negligence, errors, or omissions of your employees, agents, or
representatives at City of Sunrise, Broward County, Florida. Further, please deem this letter as
formal notice pursuant to Florida Statute Section 768.28 that Mr. Jean Baptiste is making this claim
against City of Sunrise.
On August 22", 2018, at approximately 1:37 p.m., Mr. Jean Baptiste was traveling eastbound on
Royal Palm Boulevard approaching the intersection with Parkside Avenue when your agent,
employee or servant disregarded a posted stop sign and struck Mr. Jean Baptiste’s vehicle. Mr.
Jean Baptiste suffered injuries to his face, neck, and back. He has incurred over $56,854.30 in
unpaid medical bills which was provided to Ms. Jocelyn Kiss at Florida Municipal Insurance trust
on June 27", 2019. To date, a reasonable offer of settlement has not been extended.
Pursuant to Florida Statute Section 768.28(6)(c), please be advised that Mr. Jean Baptiste was born
on 11/15/1994. Mr. Jean Baptiste’s Social Security Number is HE. Further, there are no
prior adjudicated unpaid claims in excess of $200.00 regarding this incident. Upon receipt of this
letter, please contact me so that we may discuss this claim in greater detail.
Thank you for your anticipated cooperation.
Very truly yours,Mohammed Haider, Esq.
MH:es
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Preview
Filing # 106259472 E-Filed 04/15/2020 09:33:52 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-19-026009 CHANDLER JEAN BAPTISTE, Plaintiff, vs. CITY OF SUNRISE and FRANK ANTHONY OTELLO, Defendants. / FIRST AMENDED COMPLAINT FOR DAMAGES The Plaintiff, CHANDLER JEAN BAPTISTE, by and through his/her undersigned attorney, sues the Defendants, CITY OF SUNRISE and FRANK ANTHONY OTELLO, and alleges as follows: 1. That this is an action for damages in excess of Thirty Thousand ($30,000.00) Dollars. 2. That at all times material hereto, the Plaintiff, CHANDLER JEAN BAPTISTE, was a resident of BROWARD County, Florida and is otherwise sui juris. 3. That at all times material hereto, the Defendant, FRANK ANTHONY OTELLO was a resident of BROWARD County, Florida and is otherwise sui juris. 4. That at all times material hereto, the Defendant, CITY OF SUNRISE, was a political sub-division of the State of Florida, conducting business in Broward County, Florida. 5. At all times material hereto the Defendant, CITY OF SUNRISE, was and is a political subdivision or agency of Broward County, Florida engaging in activity more particularly described below. The activity is an operational level of decision making within the 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/15/2020 09:33:52 AM.*##*Defendant. Since this activity does not involve discretionary government functions, the Defendant is not immune from tort liability. Thus, in accordance with Article X, Section 13 of the Florida Constitution, the Defendant waives sovereign immunity from liability for tort. 6. Plaintiff has complied with the notice requirement of Fla. Stat. §768.28 (exhibits A, B correspondence sent Certified Mail/Return Receipt Accepted.) 7. At all times material hereto, CITY OF SUNRISE, had an ownership, rental, bailment or leasehold interest in a 2008 Ford vehicle (“the vehicle”) with Vehicle Identification number 1FMEU63868UA88650. 8. At all times material to this action and at the time of the incident complained of, the CITY OF SUNRISE’S employee, Frank Anthony Otello, operated the subject vehicle described in the complaint. COUNT I —- NEGLIGENCE AGAINST FRANK ANTHONY OTELLO Plaintiff realleges and reincorporates each and every allegation contained in Paragraphs 1 through and including 8 above as is set forth in full and further alleges: 9. That on or about 8/22/2018, Defendant, CITY OF SUNRISE, owned a motor vehicle which was in the possession, custody and control of Defendant, FRANK ANTHONY OTELLO. 10. That Defendant, FRANK ANTHONY OTELLO, had the implied and/or expressed consent of CITY OF SUNRISE on or about 8/22/2018 to operate said motor vehicle owned by CITY OF SUNRISE. 11. That on or about 8/22/2018, Defendant, FRANK ANTHONY OTELLO, operated the motor vehicle, owned by Defendant, CITY OF SUNRISE, at or near the intersection of Royal Palm Boulevard and Parkside Avenue in Margate, Broward County, Florida.12. That at the aforesaid time and place, Defendant, FRANK ANTHONY OTELLO, owed Plaintiff and the general public a duty to operate the vehicle operated by FRANK ANTHONY OTELLO in a reasonable and safe manner and FRANK ANTHONY OTELLO breached said duty by: a. Negligently attempting a left turn without assuring that the area was clear of traffic and struck Plaintiff's vehicle; b. Negligently turned turn into Plaintiff's path and struck Plaintiff's vehicle; c. Negligently operating his vehicle in an unsafe manner and struck Plaintiff's vehicle; d. Negligently failing to keep a proper lookout and struck Plaintiff's vehicle; e. Negligently failing to abide by a traffic control device and struck Plaintiffs vehicle. 13. That as a direct and proximate result of Defendant, FRANK ANTHONY OTELLO’s, aforesaid negligence, Plaintiff, CHANDLER JEAN BAPTISTE, 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, and Plaintiff will suffer the losses in the future. WHEREFORE, the Plaintiff, CHANDLER JEAN BAPTISTE, demands judgment against the Defendant, FRANK ANTHONY OTELLO, for compensatory damages in excess of Thirty Thousand ($30,000.00) Dollars, in addition to taxable costs. Plaintiff further demands trial by jury on all issues so triable as of right by jury.COUNT II - NEGLIGENCE AGAINST CITY OF SUNRISE UNDER THE DOCTRINE OF RESPONDEAT SUPERIOR Plaintiff realleges and reincorporates each and every allegation contained in Paragraphs 1 through and including 8 above as if set forth in full, and pleads in the alternative: 14. That At all relevant times to this action, Frank Anthony Otello was an employee, agent, servant and/or independent contractor of Defendant CITY OF SUNRISE and was acting within the course and scope of that relationship. 15. That on or about 08/22/2018, Defendant, CITY OF SUNRISE owned a vehicle which was in the possession, custody and control of Defendant’s employee, Frank Anthony Otello. 16. That CITY OF SUNRISE’S employee, Frank Anthony Otello had the implied and/or expressed consent of CITY OF SUNRISE on or about 08/22/2018 to operate said vehicle owned by CITY OF SUNRISE. 17. That on or about 08/22/2018, Defendant CITY OF SUNRISE’S employee Frank Anthony Otello operated the motor vehicle, owned by Defendant, CITY OF SUNRISE, at or near the intersection of Royal Palm Boulevard and Parkside Avenue in Margate, BROWARD County, Florida. 18. That at the aforesaid time and place, Defendant’s employee Frank Anthony Otello owed Plaintiff and the general public a duty to operate the vehicle operated by CITY OF SUNRISE in a reasonable and safe manner and Frank Anthony Otello breached said duty by: a. Negligently attempting a left turn without assuring that the area was clear of traffic and struck Plaintiff's vehicle; b. Negligently turned turn into Plaintiff's path and struck Plaintiff's vehicle;c. Negligently operating his vehicle in an unsafe manner and struck Plaintiffs vehicle; d. Negligently failing to keep a proper lookout and struck Plaintiff's vehicle; e. Negligently failing to abide by a traffic control device and struck Plaintiffs vehicle. 19. That as a direct and proximate result of Defendant, CITY OF SUNRISE’s, aforesaid negligence, Plaintiff, CHANDLER JEAN BAPTISTE, 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 loss of ability to earn money. The losses are either permanent or continuing, and Plaintiff will suffer the losses in the future. WHEREFORE, Plaintiff, CHANDLER JEAN BAPTISTE, demands judgment against the Defendant, CITY OF SUNRISE, for compensatory damages in excess of Fifteen Thousand ($15,000.00) Dollars, in addition to taxable costs. Plaintiff further demands trial by jury on all issues so triable as of right by jury. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded by Electronic Mail to: E. BRUCE JOHNSON, ESQ., JOHNSON, ANSELMO, MURDOCH, BURKE, PIPER, & HOCHMAN, P.A., Attorneys for Defendant, johnson@jambg.com, this 16+ day of Aw » 20. Ze. MILLER LAW GROUP, P.A. 1937 East Atlantic Boulevard, Suite 204 Pompano Beach, Florida 33060 Telephone: (954)972-8011 Telefax: (954)782-3636Primary E-Mail: litigation@millerlaw.legal /S/ MOHAMMED HAIDER BY: MOHAMMED HAIDER Florida Bar No. 1003274EXHIBIT “A”p 1937 E. Atlantic Boulevard, Suite 204 «Pompano Beach, Florida 33060 Tel. 954.972.8011 « Fax: 954.782.3636 (MILLER LAW GROUP October 03, 2019 CERTIFIED MAIL - RETURN RECEIPT REQUESTED Article No.: 7015-0640-0002-0705-0474 Office of the City Attorney ATTN: Risk Management 10770 West Oakland Park Blvd. Sunrise, FL 33351 RE: Case Style : Chandler Jean Baptiste v. City of Sunrise Date of Accident : August 22, 2018 Claim No. : VA2018092123 Written Notice of Tort Action Pursuant to F.S. 768.26 (6 To Whom It May Concern: Please be advised that this firm has been retained to represent Mr. Chandler Jean Baptiste for injuries sustained due to the negligence, errors, or omissions of your employees, agents, or representatives at City of Sunrise, Broward County, Florida. Further, please deem this letter as formal notice pursuant to Florida Statute Section 768.28 that Mr, Jean Baptiste is making this claim against City of Sunrise. On August 22", 2018, at approximately 1:37 p.m., Mr. Jean Baptiste was traveling eastbound on Royal Palm Boulevard approaching the intersection with Parkside Avenue when your agent, employee or servant disregarded a posted stop sign and struck Mr. Jean Baptiste’s vehicle. Mr. Jean Baptiste suffered injuries to his face, neck, and back. He has incurred over $56,854.30 in unpaid medical bills which was provided to Ms. Jocelyn Kiss at Florida Municipal Insurance trust on June 27", 2019. To date, a reasonable offer of settlement has not been extended. Pursuant to Florida Statute Section 768.28(6)(c), please be advised that Mr. Jean Baptiste was born on 11/15/1994. Mr. Jean Baptiste’s Social Security Number is ME. Further, there are no prior adjudicated unpaid claims in excess of $200.00 regarding this incident. Upon receipt of this letter, please contact me so that we may discuss this claim in greater detail. Thank you for your anticipated cooperation.Very truly yours, Mohammed Haider, Esq. MH:es Page 2 of 2idjsoey winjay YSaWOg €606-000-20-06S/ NSd GLOz INdy ‘| | gE WHO Sd oo Arona peysuisey Aronyed peyouiseed HEN héehO SO20 2000 Oho Stoe i 6 WN. mUoNeunjuoy eunqeubrs [3 HPNIEG PaYOUISeY Aionyoq UO 199100 (ieqe) Bones Wo4y JejsuelL) QUINN ey °Z 101 ON konea poouson ew penes ca; «= LEER BITS 2500 TOhb ObSb Apayag @IEW PayueED DePOWISSY IEW paleIsibsy ] = Auanyjeq parousay ainjeubis ynpw/] null2W pasaysibey 2 ainyeuBis ynpy @ssaidxg [eW Awoudg 2 ad aoinias * L somag /g \SESs Aiea PAS Yao Mauve 497 Y LOI {UPWHUIN AQ VAN ON C1 :mojaq ssaippe Aronyap swe ‘s3A 31 [JU SAD [ANF Mr 0 391330 SOA [] él} Wel! Woy juelayIp Ssauppe Maniep sid :0} passauppy ej “4 i” "sywued a0eds }! ]UOJJ 8U} UO JO Kianyeg jo eq *D erfSoaH ° ‘adaldew ay} JO yORq ay) 0} PYed SIU} YOR m r ry “noA 0} Pued Oy} WINJS/ UBD OM yeu] OS easselppy [] @SJ8Ael BY} UO SSauppe Puke BWeU INOA JU w “g pue ‘Zz ‘| SW}! ajojdwW0D # INO] 0 )= SY [5 Me = Bo 4! OOD a f= 16] \ be) cE TYR PIe MN OMN(0)0 60% ORY 5 hae Fel ~1 4) 00)rr S¢ 2EEG PSTS 2900 TOhb ObSb TTA A #ONDOVAL SdSn eX0q SIU} Ul ep+q/Z pue ‘sseippe ‘aweu un aNous mv XaTIN A, OSE9|q -JEPUBS Ob-S “ON Hue Sdsn pled sae, 9 afejsog NeW Sseid-}sul4 | | | | FOINYAS WLSOd SALVLS GALINAEXHIBIT BeJe MILLER LAW GROUP 1937 E. Atlantic Boulevard, Suite 204 Pompano Beach, Florida 33060 Tel. 954.972.80116 Fax: 954.782.3636 December 09, 2019 CERTIFIED MAIL - RETURN RECEIPT REQUESTED Article No.: 7015-0640-0002-0705-2263 Florida's Department of financial services 200 E. Gaines St. Tallahassee, FL 32399 RE: Case Style : Chandler Jean Baptiste v. City of Sunrise Date of Accident : August 22, 2018 Claim No. : VA2018092123 Written Notice of Tort Acti nt to 768.26 To Whom It May Concern: Please be advised that this firm has been retained to represent Mr. Chandler Jean Baptiste for injuries sustained due to the negligence, errors, or omissions of your employees, agents, or representatives at City of Sunrise, Broward County, Florida. Further, please deem this letter as formal notice pursuant to Florida Statute Section 768.28 that Mr. Jean Baptiste is making this claim against City of Sunrise. On August 22", 2018, at approximately 1:37 p.m., Mr. Jean Baptiste was traveling eastbound on Royal Palm Boulevard approaching the intersection with Parkside Avenue when your agent, employee or servant disregarded a posted stop sign and struck Mr. Jean Baptiste’s vehicle. Mr. Jean Baptiste suffered injuries to his face, neck, and back. He has incurred over $56,854.30 in unpaid medical bills which was provided to Ms. Jocelyn Kiss at Florida Municipal Insurance trust on June 27", 2019. To date, a reasonable offer of settlement has not been extended. Pursuant to Florida Statute Section 768.28(6)(c), please be advised that Mr. Jean Baptiste was born on 11/15/1994. Mr. Jean Baptiste’s Social Security Number is HE. Further, there are no prior adjudicated unpaid claims in excess of $200.00 regarding this incident. Upon receipt of this letter, please contact me so that we may discuss this claim in greater detail. Thank you for your anticipated cooperation. Very truly yours,Mohammed Haider, Esq. 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