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08/15/2024
Open
Personal Injury and Torts - Motor Vehicle
Florida
its intersection with Wayside Drive, in unincorporated Seminole County, Florida, involving a motor vehicle owned and being operated by the Defendant, SHAWN ANDRICK BOLTON.
3. That at all times material hereto the Defendant, SHAWN ANDRICK BOLTON was residing in Oviedo, Seminole County, Florida.
4. On or about March 24, 2024 , Defendant, SHAWN ANDRICK BOLTON owned a motor vehicle, more specifically a 2016 Hyundai, bearing Vehicle License Number AW14IX and VIN Number of 5NPE24AF6GH .
5. On or about March 24, 2024 , Defendant, SHAWN ANDRICK BOLTON operated said 2016 Hyundai bearing Vehicle License Number AW14IX on the streets of the State of Florida, more specifically, to-wit: on International Parkway near its intersection with Wayside Drive, in unincorporated Seminole County, Florida.
COUNT I-NEGLIGENCE AS TO DEFENDANT, SHAWN ANDRICK BOLTON
6. The Plaintiff, LAWRENCE ARNREICH, incorporates and adopts paragraphs one (1) through five (5) and further asserts:
7. On or about the above date and at the aforesaid location, the Defendant, SHAWN ANDRICK BOLTON, operated and/or maintained his motor vehicle in a negligent and/or careless fashion SO as to cause said motor vehicle to collide with the vehicle being operated by the Plaintiff, LAWRENCE ARNREICH, severely and grievously injuring the Plaintiff, LAWRENCE ARNREICH, as a result of said collision.
8. As a direct and proximate result of the foregoing negligence of the Defendant, SHAWN ANDRICK BOLTON, the Plaintiff, LAWRENCE ARNREICH, was injured in and about his body and extremities, suffered pain and suffering and mental anguish therefrom; that he has incurred medical expenses in the treatment thereof; that he has suffered a loss of capacity for the enjoyment of life; that he has suffered one or more of the following:
Page 2(a) significant and permanent loss of an important bodily function; and/or
(b) permanent injury within a reasonable degree of medical probability, other than scarring or disfigurement; and/or
(c) significant and permanent scarring or disfigurement.
9. In addition, the Plaintiff, LAWRENCE ARNREICH, will incur further medical expense in the future; that he has suffered disability and disfigurement in the past and will continue to experience the same in the future; that he has suffered an aggravation of a pre-existing condition or injury; that one or more of the above are permanent and continuing with a reasonable degree of medical probability; that the Plaintiff, LAWRENCE ARNREICH, has suffered lost wages in the past and into the future along with the inability to earn wages into the future or the same amount of money; that the Plaintiff's vehicle was deemed a total loss as a result of the Defendant's negligence.
WHEREFORE, the Plaintiff, LAWRENCE ARNREICH,, sues the Defendant, SHAWN ANDRICKBOLTON, for compensatory damages in an amount within the jurisdictional limits of this Court, to-wit: in excess of FIFTY THOUSAND ($50,000.00) DOLLARS, exclusive of interest and costs, request an award of costs and further demand trial by jury of all issues triable as of right by a jury.
Dated: August 15, 2024
Wieland & DeLattre, P.A. - Fax Attorneys for Plaintiffs
/s/ WILLIAM J. WIELAND, II William J. Wieland, II Florida Bar #
Page 3DONNA M GOERNER
LAWRENCE ARNREICH
SHAWN ANDRICK BOLTON
WILLIAM WIELAND II
BRENDA COMBS
03/03/2025: NOTICE OF SERVICE OF INITIAL DISCLOSURES BY DEFT
03/03/2025: NOTICE OF APPEARANCE & DESIGNATION OF EMAIL ADDRESS BY BRENDA M COMBS ESQ OBO DEFT
03/06/2025: RESPONSE TO REQUEST FOR ADMISSION BY DEFT
02/25/2025: REPLY TO AFFIRMATIVE DEFENSES & MOTION TO STRIKE BY PLTF
02/07/2025: ANSWER AND AFFIRMATIVE DEFENSES & DEMAND FOR JURY TRIAL BY DEFT
01/22/2025: AFFIDAVIT OF COMPLIANCE WITH ATTACHED SUSD ON AMENDED - SHAWN ANDRICK BOLTON 1/3/25BY PLTF
01/22/2025: NOTICE OF FILING EXHIBIT RETURN RECEIPT RETURN TO SENDER - BY PLTF
01/07/2025: ACCEPTANCE OF SERVICE FOR SHAWN ANDRICK BOLTON 12/30/24 ON AMENDED
12/09/2024: AMENDED COMPLAINT FILED
10/29/2024: MOTION FOR ENLARGEMENT/EXTENSION OF TIME TO PERFECT SERVICE OF PROCESS BY PLTF
11/07/2024: LETTER TO JUDGE GOERNER REGARDING PROPOSED ORDER
08/15/2024: CIVIL COVER SHEET
08/15/2024: COMPLAINT FILED
08/15/2024: SUMMONS ISSUED - SHAWN ANDRICK BOLTON
08/15/2024: PHOTOCOPIED DOCUMENT OF CASE MANAGEMENT PLAN & ORDER
08/15/2024: REQUEST FOR ADMISSIONS TO DEFT
08/15/2024: REQUEST FOR PRODUCTION TO DEFT
08/15/2024: NOTICE OF SERVICE OF INTERROGATORIES TO DEFT
DocketRESPONSE TO REQUEST FOR ADMISSION BY DEFT
[-] Read LessDocketNOTICE OF APPEARANCE & DESIGNATION OF EMAIL ADDRESS BY BRENDA M COMBS ESQ OBO DEFT
[-] Read LessDocketNOTICE OF SERVICE OF INITIAL DISCLOSURES BY DEFT
[-] Read LessDocketREPLY TO AFFIRMATIVE DEFENSES & MOTION TO STRIKE BY PLTF
[-] Read LessDocketANSWER AND AFFIRMATIVE DEFENSES & DEMAND FOR JURY TRIAL BY DEFT
[-] Read LessDocketNOTICE OF FILING EXHIBIT RETURN RECEIPT RETURN TO SENDER - BY PLTF
[-] Read LessDocketAFFIDAVIT OF COMPLIANCE WITH ATTACHED SUSD ON AMENDED - SHAWN ANDRICK BOLTON 1/3/25BY PLTF
[-] Read LessDocketACCEPTANCE OF SERVICE FOR SHAWN ANDRICK BOLTON 12/30/24 ON AMENDED
[-] Read LessDocketAMENDED COMPLAINT FILED
DocketSUMMONS ISSUED ON AMENDED COMPLAINT TO SHAWN ANDRICK BOLTON 12/09/2024
[-] Read LessDocketORDER EXTENDING TIME TO PERFECT SERVICE OF PROCESS / GRANTED - JUDGE GOERNER 11/20/24
[-] Read LessDocketLETTER TO JUDGE GOERNER REGARDING PROPOSED ORDER
[-] Read LessDocketMOTION FOR ENLARGEMENT/EXTENSION OF TIME TO PERFECT SERVICE OF PROCESS BY PLTF
[-] Read LessDocketNOTICE OF SERVICE OF INTERROGATORIES TO DEFT
[-] Read LessDocketREQUEST FOR PRODUCTION TO DEFT
[-] Read LessDocketREQUEST FOR ADMISSIONS TO DEFT
[-] Read LessDocketPHOTOCOPIED DOCUMENT OF CASE MANAGEMENT PLAN & ORDER
[-] Read LessDocketSUMMONS ISSUED - SHAWN ANDRICK BOLTON
[-] Read LessDocketCOMPLAINT FILED
DocketCIVIL COVER SHEET