JENNIFER MCFARLAND -VS- FEDERICO PAGANI GONZALEZ

4. At all times material to this action, Defendant, ANA GONZALEZ LIPSCHITZ, was a natural person residing in Coral Springs, Broward County, Florida.

5. The Eighteenth Judicial Circuit Court has venue pursuant to Florida Statutes, 47.011 because the cause of action occurred in Rockledge, Brevard County, Florida.

FACTS

6. On or about June 19, 2024 , the Plaintiff, JENNIFER MCFARLAND, was operating a motor vehicle on or near E Altamonte Drive and the intersection of Anchor Rd in Altamonte Springs, Seminole County, Florida.

7. At that time and place, Defendant, FEDERICO PAGANI GONZALEZ, was operating a motor vehicle with the knowledge and consent of its owner, Defendant ANA GONZALEZ LIPSCHITZ, traveling on E Altamonte Drive and the intersection of Anchor Rd in Altamonte Springs, Seminole County, Florida. Defendant FEDERICO PAGANI GONZALEZ negligently operated and/or maintained the motor vehicle SO that it collided with the vehicle containing Plaintiff, JENNIFER MCFARLAND.

8. At all relevant times, the Plaintiff did not contribute in any way to the crash or her injuries.

9. Defendant FEDERICO PAGANI GONZALEZ acted in a manner that directly and proximately caused the crash and the resulting injuries to the Plaintiff.

10. As a result of the crash, the Plaintiff suffered bodily injury including permanent injuries to the body as a whole, pain and suffering of both a physical and mental nature, disability, physical impairment, disfigurement, mental anguish, inconvenience, loss of capacity

for the enjoyment of life, aggravation of an existing condition, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of the ability to earn money and loss of the ability to lead and enjoy a normal life. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. Plaintiff's motor vehicle was also damaged.

11. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 10, above.

12. Defendant, FEDERICO PAGANI GONZALEZ, owed a Plaintiff, JENNIFER MCFARLAND, the duty to operate the motor vehicle she was driving in a safe, careful and prudent manner SO as not to collide with the vehicle containing Plaintiff, JENNIFER MCFARLAND.

13. Defendant, FEDERICO PAGANI GONZALEZ, breached that duty by carelessly and negligently operating the motor vehicle in such a manner that it caused a collision with the vehicle containing Plaintiff, JENNIFER MCFARLAND.

14. As a direct and proximate result of Defendant, FEDERICO PAGANI GONZALEZ'S negligence, Plaintiff suffered the damages described in Paragraph 10, above.

15. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 10 above.

16. At the time and place, Defendant, FEDERICO PAGANI GONZALEZ was operating a motor vehicle owned by Defendant, ANA GONZALEZ LIPSCHITZ, in Seminole County, Florida.