QUIOVANA CRAIG VS GABRIEL BOLDEN Et Al

of employment with HICKMAN TRANSPORT CO INC and traveling eastbound on Commonwealth Avenue near Interstate 295 in Duval County, Florida. Defendant, GABRIEL BOLDEN, failed to yield while attempting a left turn, causing a collision with Plaintiff, QUIOVANA CRAIG's, vehicle.

6. At all times material to this action, the subject truck driven by Defendant GABRIEL BOLDEN, was a commercial motor vehicle and subject to regulations promulgated by the Federal Motor Carrier Safety Administration (FMCSA).

7. The incident giving rise to this action occurred in Duval County, Florida.

8. Venue is proper in this Court pursuant to F.S.A. 47.051.

The Plaintiff realleges and incorporates the allegations of paragraphs 1 through 8 above and further alleges:

9. On April 19, 2023 , Plaintiff, QUIOVANA CRAIG, was traveling westbound on Commonwealth Avenue near Interstate 295 in Duval County, Florida

10. At that time and place, Defendant, GABRIEL BOLDEN, was operating a tractor- trailer owned by Defendant, HICKMAN TRANSPORT CO INC, while in the course and scope of employment with HICKMAN TRANSPORT CO INC and traveling eastbound on Commonwealth Avenue near Interstate 295 in Duval County, Florida. Defendant, GABRIEL BOLDEN, failed to yield while attempting a left turn, causing a collision with Plaintiff, QUIOVANA CRAIG's, vehicle.

Plaintiff, QUIOVANA CRAIG, realleges and incorporates by reference each and every allegation contained in Paragraphs 1 through 10 above, and further states:

11. At the time and place of the incident, Defendant, GABRIEL BOLDEN, negligently operated and/or maintained the motor vehicle causing a collision with Plaintiff's motor vehicle.

12. At the time and place of the aforementioned incident Defendant, GABRIEL BOLDEN, was guilty of one or more of the following negligent acts or negligent omissions which caused or contributed to the cause of the Plaintiff's injuries and damages which acts and omissions are set out herein by way of illustration and not limitation:

(a) Driving carelessly in violation of Florida Statute $316. 1925 ;

(b) Failing to obey Florida's traffic laws in violation of Florida Statute $316.072;

(c) Failing to keep a proper lookout;

(d) Driving the vehicle while distracted;

(e) Driving the vehicle while fatigued;

(f) Exceeding hours of service limitations in violation of 49 CFR 395.1(g);

(g) Failing to maintain control of the vehicle;

(h) Failing to take appropriate evasive action;

(i) Failing to properly inspect the vehicle in violation of 49 CFR 396.11;

(j) Failing to maintain the vehicle in proper repair in violation of 49 CFR 396.1;

(k) Failing to exercise reasonable care under all of the surrounding circumstances; and

(1) Failing to make a proper turn in violation of Florida Statute $316.151.