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Filing # 55816871 E-Filed 05/01/2017 04:40:05 PM
IN THE CIRCUIT COURT OF THE 9TH
JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
AURORA ANN PORTER, CASE NO.:
Plaintiff,
v.
ORLANDO UTILITIES COMMISSION,
Defendant.
_________________________________/
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff, AURORA ANN PORTER, by and through their undersigned counsel, sues the
Defendant, ORLANDO UTILITIES COMMISSION, and alleges the following:
1. This is an action for damages in excess of the sum of Fifteen Thousand
($15,000.00) Dollars, exclusive of interest, costs, and attorney fees.
2. At all times material herein Plaintiff, AURORA ANN PORTER, was and is a
resident of Orange County, Florida.
3. At all times material to this action, Defendant, ORLANDO UTILITES
COMMISSION, is a Governmental Entity doing business in Orange County, Florida.
4. At all times material herein, Plaintiff, AURORA ANN PORTER, has complied
with all applicable pre-suit requirements as stated in Florida Statute 768.28.
5. Venue is proper in Orange County because the alleged incident occurred in
Orange County.
FACTS COMMON TO ALL COUNTS
6. On April 2, 2016, Maniram Bhim, was an employee, agent and/or apparent agent
of the Defendant, ORLANDO UTILITIES COMMISSION, driving a “2015” Ford bearing
license plate number YI763 within the scope of his employment, and with the permission,
consent and authorization of Defendant, ORLANDO UTILITIES COMMISSION.
7. On April 2, 2016, Plaintiff, AURORA ANN PORTER, was the driver of a vehicle
traveling westbound on East Livingston Street in Orlando, Orange County, Florida.
8. On April 2, 2016, Maniram Bhim, acting within the scope of his employment,
agency and/or apparent agency of Defendant, ORLANDO UTILITIES COMMISSION,
negligently operated and/or maintained the “2015” Ford vehicle by failing to stop at a stop sign,
failure to keep a proper lookout, and failing to yield the right of way thereby colliding with the
vehicle driven by Plaintiff, AURORA ANN PORTER.
9. As a direct and proximate result of the negligence of an employee of the
Defendant, ORLANDO UTILITIES COMMISSION, Plaintiff, AURORA ANN PORTER, was
caused to suffer significant bodily injury, 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, Plaintiff, AURORA ANN PORTER, sues Defendant, ORLANDO
UTILITIES COMMISSION, for compensatory damages in excess of the sum of Fifteen
Thousand ($15,000.00) Dollars, plus costs; and further demand trial by jury of all issues triable
as of right by jury.
DATED this 1st day of May, 2017.
REIFKIND THOMPSON & RUDZINSKI, LLP.
Counsel for Plaintiffs
808 Mabbette Street
Kissimmee, Florida 34741
Telephone: (407) 343 – 5152
Facsimile: (407) 944 – 1609
Email: mrabin@rtrlaw.com
LSepot-Green@rtrlaw.com
By: /s Matthew A. Rabin______________
Matthew A. Rabin, Esq.
Florida Bar No. 810681
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Filing # 55816871 E-Filed 05/01/2017 04:40:05 PM IN THE CIRCUIT COURT OF THE 9TH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA AURORA ANN PORTER, CASE NO.: Plaintiff, v. ORLANDO UTILITIES COMMISSION, Defendant. _________________________________/ COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff, AURORA ANN PORTER, by and through their undersigned counsel, sues the Defendant, ORLANDO UTILITIES COMMISSION, and alleges the following: 1. This is an action for damages in excess of the sum of Fifteen Thousand ($15,000.00) Dollars, exclusive of interest, costs, and attorney fees. 2. At all times material herein Plaintiff, AURORA ANN PORTER, was and is a resident of Orange County, Florida. 3. At all times material to this action, Defendant, ORLANDO UTILITES COMMISSION, is a Governmental Entity doing business in Orange County, Florida. 4. At all times material herein, Plaintiff, AURORA ANN PORTER, has complied with all applicable pre-suit requirements as stated in Florida Statute 768.28. 5. Venue is proper in Orange County because the alleged incident occurred in Orange County. FACTS COMMON TO ALL COUNTS 6. On April 2, 2016, Maniram Bhim, was an employee, agent and/or apparent agent of the Defendant, ORLANDO UTILITIES COMMISSION, driving a “2015” Ford bearing license plate number YI763 within the scope of his employment, and with the permission, consent and authorization of Defendant, ORLANDO UTILITIES COMMISSION. 7. On April 2, 2016, Plaintiff, AURORA ANN PORTER, was the driver of a vehicle traveling westbound on East Livingston Street in Orlando, Orange County, Florida. 8. On April 2, 2016, Maniram Bhim, acting within the scope of his employment, agency and/or apparent agency of Defendant, ORLANDO UTILITIES COMMISSION, negligently operated and/or maintained the “2015” Ford vehicle by failing to stop at a stop sign, failure to keep a proper lookout, and failing to yield the right of way thereby colliding with the vehicle driven by Plaintiff, AURORA ANN PORTER. 9. As a direct and proximate result of the negligence of an employee of the Defendant, ORLANDO UTILITIES COMMISSION, Plaintiff, AURORA ANN PORTER, was caused to suffer significant bodily injury, 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, Plaintiff, AURORA ANN PORTER, sues Defendant, ORLANDO UTILITIES COMMISSION, for compensatory damages in excess of the sum of Fifteen Thousand ($15,000.00) Dollars, plus costs; and further demand trial by jury of all issues triable as of right by jury. DATED this 1st day of May, 2017. REIFKIND THOMPSON & RUDZINSKI, LLP. Counsel for Plaintiffs 808 Mabbette Street Kissimmee, Florida 34741 Telephone: (407) 343 – 5152 Facsimile: (407) 944 – 1609 Email: mrabin@rtrlaw.com LSepot-Green@rtrlaw.com By: /s Matthew A. Rabin______________ Matthew A. Rabin, Esq. Florida Bar No. 810681