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Filing # 56452049 E-Filed 05/15/2017 04:29:29 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
BRENTLEY M. HUXTABLE,
Case No.:
Plaintiff,
vs.
CARLOS E. RESUMIL,
Defendant.
COMPLAINT
COMES NOW the Plaintiff, BRENTLEY M. HUXTABLE, by and through
undersigned counsel and sues Defendant, CARLOS E. RESUMIL, and says:
1. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000.00).
2. At all times material to this action, Plaintiff, BRENTLEY M. HUXTABLE, was a
natural person residing in Orlando, Orange County, Florida.
3. At all times material to this action, Defendant, CARLOS E. RESUMIL, was a
natural person residing in Belen de Escobar in Buenos Aires, Argentina.
4. Venue is proper in Orange County, Florida pursuant to Florida Statute Section
47.011.
5. The event, a motor vehicle accident, which gives rise to this action occurred in
Orlando, Orange County, Florida.
6. On or about October 1, 2016, Plaintiff, BRENTLEY M. HUXTABLE, was
operating a motor vehicle on Universal Boulevard and Hollywood Way in Orlando, Orange
County, Florida.
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7. At said time and place, the Defendant, CARLOS E. RESUMIL, operated a motor
vehicle owned and maintained by Sixt Rent a Car., a foreign Limited Liability Corporation doing
business in Florida, at or near the crash location which collided with Plaintiff’s motor vehicle.
8. At said time and place Defendant, CARLOS E. RESUMIL, negligently operated
said motor vehicle so that it collided with the Plaintiff, BRENTLEY M. HUXTABLE’s, vehicle
being driven by Plaintiff.
9. All necessary conditions precedent to the commencement of this action have been
either satisfied or waived.
CLAIM OF BRENTLEY M. HUXTABLE AGAINST CARLOS E. RESUMIL
10. Plaintiff, BRENTLEY M. HUXTABLE, realleges and incorporates by reference
paragraphs 1-9 as fully set forth herein.
11. Defendant, CARLOS E. RESUMIL, was negligent by operating said motor vehicle
in a negligent and careless manner so as to cause it to collide with a vehicle then and there
operated by Plaintiff, BRENTLEY M. HUXTABLE.
12. As a direct and proximate result of the said negligent operation of the
said motor vehicle by Defendant, CARLOS E. RESUMIL; the Plaintiff, BRENTLEY M.
HUXTABLE, has suffered bodily injury, and resulting pain and suffering, disability,
disfigurement, mental anguish and pain, loss of earnings, loss of ability to earn money and
aggravation of a previously existing condition and has incurred substantial medical expenses for
treatment and care, past, present and future. Said losses, injuries and expenses are either
permanent or continuing in nature and Plaintiff, BRENTLEY M. HUXTABLE will continue to
suffer same in the future. Further, said Plaintiff, was caused to suffer damages to his automobile.
WHEREFORE, Plaintiff, BRENTLEY M. HUXTABLE, demands judgment for damages
against Defendant, CARLOS E. RESUMIL and such other relief as this Court deems just and
proper.
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DEMAND FOR JURY TRIAL
Plaintiff, BRENTLEY M. HUXTABLE, hereby respectfully requests this Court allow a
jury trial on all issues so triable.
Dated this 15th day of May, 2017.
//s// John Watson
____________________________________
John Allan Watson, Esquire
Florida Bar Number 92596
Travis J. McMillen, Esquire
Florida Bar Number 0185655
BOGIN, MUNNS & MUNNS, P.A.
Gateway Center
1000 Legion Place, Suite 1000
Orlando, Florida 32801
Tel: 407-578-9696
Fax: 407-241-3800
Primary: jwatson@boginmunns.com
Secondary: storres@boginmunns.com
bmmservice@boginmunns.com
Attorneys for Plaintiff
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Preview
Filing # 56452049 E-Filed 05/15/2017 04:29:29 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION BRENTLEY M. HUXTABLE, Case No.: Plaintiff, vs. CARLOS E. RESUMIL, Defendant. COMPLAINT COMES NOW the Plaintiff, BRENTLEY M. HUXTABLE, by and through undersigned counsel and sues Defendant, CARLOS E. RESUMIL, and says: 1. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000.00). 2. At all times material to this action, Plaintiff, BRENTLEY M. HUXTABLE, was a natural person residing in Orlando, Orange County, Florida. 3. At all times material to this action, Defendant, CARLOS E. RESUMIL, was a natural person residing in Belen de Escobar in Buenos Aires, Argentina. 4. Venue is proper in Orange County, Florida pursuant to Florida Statute Section 47.011. 5. The event, a motor vehicle accident, which gives rise to this action occurred in Orlando, Orange County, Florida. 6. On or about October 1, 2016, Plaintiff, BRENTLEY M. HUXTABLE, was operating a motor vehicle on Universal Boulevard and Hollywood Way in Orlando, Orange County, Florida. Page 1 of 3 7. At said time and place, the Defendant, CARLOS E. RESUMIL, operated a motor vehicle owned and maintained by Sixt Rent a Car., a foreign Limited Liability Corporation doing business in Florida, at or near the crash location which collided with Plaintiff’s motor vehicle. 8. At said time and place Defendant, CARLOS E. RESUMIL, negligently operated said motor vehicle so that it collided with the Plaintiff, BRENTLEY M. HUXTABLE’s, vehicle being driven by Plaintiff. 9. All necessary conditions precedent to the commencement of this action have been either satisfied or waived. CLAIM OF BRENTLEY M. HUXTABLE AGAINST CARLOS E. RESUMIL 10. Plaintiff, BRENTLEY M. HUXTABLE, realleges and incorporates by reference paragraphs 1-9 as fully set forth herein. 11. Defendant, CARLOS E. RESUMIL, was negligent by operating said motor vehicle in a negligent and careless manner so as to cause it to collide with a vehicle then and there operated by Plaintiff, BRENTLEY M. HUXTABLE. 12. As a direct and proximate result of the said negligent operation of the said motor vehicle by Defendant, CARLOS E. RESUMIL; the Plaintiff, BRENTLEY M. HUXTABLE, has suffered bodily injury, and resulting pain and suffering, disability, disfigurement, mental anguish and pain, loss of earnings, loss of ability to earn money and aggravation of a previously existing condition and has incurred substantial medical expenses for treatment and care, past, present and future. Said losses, injuries and expenses are either permanent or continuing in nature and Plaintiff, BRENTLEY M. HUXTABLE will continue to suffer same in the future. Further, said Plaintiff, was caused to suffer damages to his automobile. WHEREFORE, Plaintiff, BRENTLEY M. HUXTABLE, demands judgment for damages against Defendant, CARLOS E. RESUMIL and such other relief as this Court deems just and proper. Page 2 of 3 DEMAND FOR JURY TRIAL Plaintiff, BRENTLEY M. HUXTABLE, hereby respectfully requests this Court allow a jury trial on all issues so triable. Dated this 15th day of May, 2017. //s// John Watson ____________________________________ John Allan Watson, Esquire Florida Bar Number 92596 Travis J. McMillen, Esquire Florida Bar Number 0185655 BOGIN, MUNNS & MUNNS, P.A. Gateway Center 1000 Legion Place, Suite 1000 Orlando, Florida 32801 Tel: 407-578-9696 Fax: 407-241-3800 Primary: jwatson@boginmunns.com Secondary: storres@boginmunns.com bmmservice@boginmunns.com Attorneys for Plaintiff Page 3 of 3