Arlett Garza vs Luisa Olivieri

2. The 11th Judicial Circuit Court has venue pursuant to Florida Statutes, 47.011 because the cause of action occurred in Miami-Dade County, Florida.

3. At all times material to this action, Plaintiff, ARLETT GARZA, was a natural person residing in Miami-Dade County, Florida.

4. At all times material to this action, Defendant, LUISA OLIVIERI, was a natural person residing in Miami-Dade County, Florida.

5. On or about 10/17/ 2023 , Plaintiff, ARLETT GARZA, was the operator of a motor vehicle in Miami-Dade County, Florida.

6. At that time and place, LUISA OLIVIERI, was the operator of a motor vehicle in Miami- Dade County, Florida.

7. At that time and place, LUISA OLIVIERI, negligently operated and/or maintained the motor vehicle such that it collided with the motor vehicle operated by Plaintiff, ARLETT GARZA.

Plaintiff, ARLETT GARZA, reiterates and realleges Paragraphs 1 through 7 as if more fully set forth herein and further alleges:

8. The Defendant, LUISA OLIVIERI, was negligent and breached the duty owed to Plaintiff, ARLETT GARZA, by committing one or more of the following:

a) Negligently operated the motor vehicle in a negligent manner, which caused said accident.

b) Negligently failed to ensure that he was knowledgeable regarding rules and laws concerning operating the motor vehicle.

9. As a direct and proximate result of the negligence of Defendant, LUISA OLIVIERI,

Plaintiff, ARLETT GARZA, suffered bodily injury including a permanent injury 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 ability to earn money and loss of ability to lead and enjoy a normal life. The losses are either permanent or continuing and Plaintiff, ARLETT GARZA, will suffer the losses in the future. Plaintiff, ARLETT GARZA, will suffer or incur the injuries, expenses and impairment in the future.

WHEREFORE, the Plaintiff, ARLETT GARZA, demands judgment against the Defendant, LUISA OLIVIERI, in an amount in excess of Fifty Thousand ($50,000) Dollars, and requests a trial by jury of all issues triable as of right by a jury.

RESPECTFULLY submitted this 9th day of June 2024 .

s/ Marcel Flemming Marcel Flemming, Esq. Florida Bar No.: Morgan & Morgan, P.A. P: Attorney for Plaintiff