Socorro Santos vs Nahum Chery et al

3. At all times material hereto, Defendant, NAHUM CHERY, was a resident of Miami, Miami-Dade County, Florida.

4. At all times material to this action, the Defendant, TESLA, INC., was and is a for- profit corporation authorized to do and doing business in Florida.

5. On or about March 8, 2024 , Plaintiff, SOCORRO SANTOS, was the passenger of a vehicle traveling at or near Interstate 95 North and NW 135th St., North Miami, Miami-Dade County, Florida.

Plaintiff, SOCORRO SANTOS, reiterates and re-alleges Paragraphs 1 through 5 as if more fully set forth herein and further alleges:

6. At that time and place Defendant, NAHUM CHERY, negligently operated or maintained the motor vehicle owned by Defendant, TESLA, INC., SO that it collided with the motor- vehicle occupied by Plaintiff, SOCORRO SANTOS,

7. As a result, Plaintiff, SOCORRO SANTOS, suffered bodily injury and resulting 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 and Plaintiff will suffer the losses in the future.

8. WHEREFORE, Plaintiff, SOCORRO SANTOS, demands judgment against the Defendant, NAHUM CHERY, in an amount in excess of Fifty Thousand ($50,000.00) Dollars, and requests a trial by jury of all issues triable as of right by a jury.

Plaintiff, SOCORRO SANTOS, reiterates and re-alleges Paragraphs 1 through 5 as if more fully set forth herein and further alleges:

9. By virtue of the fact that Defendant, TESLA, INC., owned the motor vehicle driven by Defendant, NAHUM CHERY, consented and gave permission to the driver to drive the motor vehicle, Defendant, TESLA, INC., is liable for the driver's negligent acts.

10. As a result, Plaintiff, SOCORRO SANTOS, suffered bodily injury and resulting 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 and Plaintiff will suffer the losses in the future.

WHEREFORE, the Plaintiff, SOCORRO SANTOS, demands judgment against the Defendant, TESLA, INC., in an amount in excess of Fifty Thousand ($50,000.00) Dollars, and requests a trial by jury of all issues triable as of right by a jury.

Plaintiff, SOCORRO SANTOS, reiterates and re-alleges Paragraphs 1 through 5 as if more fully set forth herein and further alleges:

11. At that time and place, Defendant, NAHUM CHERY, was operating the motor- vehicle during the course and scope of her employment with Defendant, TESLA, INC..

12. At all relevant times, Defendant, NAHUM CHERY, was the employee, agent, servant, and/or statutory employee for TESLA, INC., operating for the benefit of, in furtherance of