Filing # 193626063 E-Filed 03/08/2024 01:17:55 PM

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR

ORANGE COUNTY FLORIDA

CASE NO.:

M1KEANESHA MOORE, individually,

RAVEN R. FONDIA, her husband,
And on behalf of
R.R.F, a minor child,
R.L.F, a minor child, and
R.M.F, a minor child.

Plaintiffs,

VS.

SPT WAH WOODHILL LLC,

A Foreign Limited Liability Company,
HIGHMARK RESIDENTIAL, LLC,
A Foreign Limited Liability Company, and
LAKE APOPKA NATURAL GAS DISTRICT
A Florida governmental entity.
Defendants.
/

COMPLAINT

COMES NOW, the Plaintiffs, by and through their undersigned attorney, and sues

the Defendants, alleging as follows:

GENERAL ALLEGATIONS

1. This is an action for damages in excess of the jurisdictional amount of

$75,000.00 for filing in circuit court, exclusive of costs and interest, with the full extent
of the Plaintiffsmonetary damages undetermined at this time.
2. At all times material hereto, the Plaintiffs were residents of Orange

County, Florida. Plaintiff MIKEANESHA MOORE is married to her husband, RAVEN

F. FONDIA and they have three minor children listed as Plaintiffs with their identities

protected for privacy.

3. At all times material hereto, the Defendant, SPT WAH WOODHILL LLC
was a foreign LLC doing business in Orange County, Florida which owned the apartment
complex known as Woodhill Apartments located at 7200 Woodhill Park Drive in

Orlando, Florida. Jurisdiction is proper under Florida Statute §48.193(1)(a)(1). As the

cause of action occurred in Orange County, FL venue is proper under Florida Statute

§47.051.
4. At all times material hereto, the Defendant, HIGHMARK

RESIDENTIAL, LLC was a foreign LLC doing business in Orange County, Florida
which managed the premises known as Woodhill Apartments located at 7200 Woodhill
Park Drive in Orlando, Florida. Jurisdiction is proper under Florida Statute

§48.193(1)(a)(1). As the cause of action occurred in Orange County, FL venue is proper

under Florida Statute §47.051.

5. At all times material hereto, the Defendant LAKE APOPKA NATURAL
GAS DISTRICT is a governmental entity which owns, operates and maintains natural gas
distribution services in various municipalities in the State of Florida. Jurisdiction is

proper under Florida Statute §48.193(1)(a)(1) and Florida Statute §768.28. As the cause

of action occurred in Orange County, FL venue is proper under Florida Statute §47.011.

6. This cause of action occurred at 7300 Woodhill Park, Apartment 616, in

Orlando, Florida on March 1st, 2024 around 9:33 a.m.

7. On or about this time the Plaintiff MIKEANESHA MOORE returned

home and entered her apartment building. Upon entering the apartment MIKEANESHA
MOORE was catastrophically burned by a gas fire explosion. MIKEANESHA MOORE
suffered horrifically painful 3rd and 4th degree burns on over 40% of her body causing her

to be placed in hospital critical care, immobilized and unable to speak. MIKEANESHA

MOORE will require multiple surgeries for the next several years of her life for the

catastrophic burns caused by the gas explosion. During the investigation of the
aforementioned gas explosion the local fire department and agents of the Defendants

immediately noticed an uncapped and unplugged gas line in the laundry room of the
Plaintiffsapartment. It has been determined that the explosion started in the laundry
room as a result of gas leaking from this illegally unplugged and uncapped gas line which
had remained hazardous since the Plaintiffs began their lease.

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 COUNT I: NEGLIGENCE OF SPT WAH WOODHILL LLC
8. Plaintiff re-alleges and incorporates herein paragraphs 1-7 and further

alleges:
9. SPT WAH WOODHILL LLC was the legal owner of the apartment

complex located at 7200 Woodhill Park Drive in Orlando, Florida and leased residential
dwelling spaces to the public. SPT WAH WOODHILL LLC had a non-delegable duty to
exercise reasonable care and protect the Plaintiffs from reasonably foreseeable harm.

These duties include providing the Plaintiffs a safe apartment with safe natural gas

connections and appliances free of gas leaks in adherence to the Florida Statutes, Florida

building codes, National Fuel Gas Code and the Code of Federal Regulations. The
Plaintiff SPT WAH WOODHILL LLC breached these duties and had actual or

constructive notice of these dangers in one or more of the following ways:

a). Allowing the Plaintiffs to move into an apartment that contained unplugged
and uncapped gas lines and had not been properly inspected for uncapped and unplugged

gas lines;

b). Failing to take reasonably safe precautions after many complaints from tenants
over months and years of gas smells, gas leaks and other evidence of unsafe gas lines
from multiple units in the Woodhill apartment complex;

d). Failing to warn the Plaintiffs and tenants that they had been provided an

apartment that had not been inspected for uncapped and unplugged gas lines;

e). Allowing tenants, employees, agents and other unlicensed gas contractors to
remove gas appliances without capping and plugging gas lines and/or taking other

necessary safety precautions with gas lines and gas appliances;

f). Failing to utilize license gas contractors for all installation, repairs and
maintenance of gas appliances and/or gas lines;

g). Failing to order safety inspection checks for their rental units;
h). Failing to inspect the property and rental units for potential gas leaks,

uncapped gas lines and unplugged gas lines;

i). Failing to meet industry standards, statutes, building and gas codes for the
rental units;

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 j). Failing to cap and/or plug gas lines after appliances were disconnected by a

previous tenant;
k). Failing to properly notify the Defendant LAKE APOPKA NATURAL GAS
DISTRICT and take appropriate action after complaints from residents about gas smells
and other evidence of gas leaks on the premises;

10. As a direct and proximate result of the negligence of the Defendant SPT
WAH WOODHILL LLC the Plaintiff MIKEANESHA MOORE suffered bodily injury

resulting in pain and suffering, disability, disfigurement, aggravated a pre-existing

condition or activated a pre-existing condition, mental anguish, loss of the capacity for
the enjoyment of life, medical expenses, travel expenses for medical treatment, loss of

earnings, and loss of the capacity to earn. These losses are either permanent or

continuing in nature, and the Plaintiff MIKEANESHA MOORE will suffer the losses in
the future.

WHEREFORE, the Plaintiff MIKEANESHA MOORE demands judgment against

the Defendant in excess of the jurisdictional amount for filing in the circuit court,
exclusive of costs and interest, and requests a jury trial.

COUNT II —
LOSS OF CONSORTIUM OF RAVEN FONDIA;
NEGLIGENCE OF SPT WAH WOODHILL LLC
11. Plaintiffs re-allege and incorporate herein paragraphs 1-10 and further allege:
12. At all times material, RAVEN FONDIA was the husband of MIKEANESHA

MOORE and therefore entitled to her care, comfort, support and society.
13. As a direct and proximate result of the Defendant SPT WAH WOODHILL
LLC's negligence in causing his wife's injury, RAVEN FONDIA has been permanently

deprived of his wife's care, comfort, support and society.

WHEREFORE, the Plaintiff RAVEN FONDIA demands judgment against the
Defendant SPT WAH WOODHILL LLC in excess of the jurisdictional amount for filing
in the circuit court, exclusive of costs and interest, and requests a jury trial.

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 COUNT III- CLAIM OF RRF —
FLORIDA STATUTE 768.0415;
NEGLIGENCE OF SPT WAH WOODHILL LLC
14. Plaintiffs as natural parents and guardians on behalf of RRF, a minor, re-

allege and incorporate herein paragraphs 1-10 and further allege:

15. At all times material RRF is a minor child whose name has been redacted for

privacy and was born on 4/2/2010. RRF is an unmarried dependent of MIKEANESHA

MOORE.
16. Pursuant to Florida law a defendant who, through negligence, causes

significant permanent injury to the natural or adoptive parent of an unmarried dependent

resulting in a permanent total disability shall be liable to the dependent for damages,
including damages for permanent loss of services, comfort, companionship, and society.
17. The Defendant SPT WAH WOODHILL LLC has caused such significant

permanent injury upon Plaintiff MIKEANESHA MOORE and as such RRF, a minor
child is entitled to damages for permanent loss of services, comfort, companionship, and

society.
WHEREFORE, the Plaintiff RRF demands judgment against the Defendant SPT
WAH WOODHILL LLC in excess of the jurisdictional amount for filing in the circuit

court, exclusive of costs and interest, and requests a jury trial.

COUNT IV- CLAIM OF RLF —

FLORIDA STATUTE 768.0415;
NEGLIGENCE OF SPT WAH WOODHILL LLC
18. Plaintiffs as natural parents and guardians on behalf of RLF, a minor, re-allege
and incorporate herein paragraphs 1-10 and further allege:

19. At all times material RLF is a minor child whose name has been redacted for

privacy and was born on 01/01/2015. RLF is an unmarried dependent of MIKEANESHA

MOORE.
20. Pursuant to Florida law a defendant who, through negligence, causes

significant permanent injury to the natural or adoptive parent of an unmarried dependent

resulting in a permanent total disability shall be liable to the dependent for damages,
including damages for permanent loss of services, comfort, companionship, and society.
 21. The Defendant SPT WAH WOODHILL LLC has caused such significant
permanent injury upon Plaintiff MIKEANESHA MOORE and as such RLF, a minor
child is entitled to damages for permanent loss of services, comfort, companionship, and

society.
WHEREFORE, the Plaintiff RLF demands judgment against the Defendant SPT
WAH WOODHILL LLC in excess of the jurisdictional amount for filing in the circuit
court, exclusive of costs and interest, and requests a jury trial.

COUNT V- CLAIM OF RMF —

FLORIDA STATUTE 768.0415;
NEGLIGENCE OF SPT WAH WOODHILL LLC
22. Plaintiffs as natural parents and vardians on behalf of RMF, a minor, re-

allege and incorporate herein paragraphs 1-10 and further allege:

23. At all times material RMF is a minor child whose name has been redacted for

privacy and was born on 4/10/2019. RMF is an unmarried dependent of MIKEANESHA

MOORE.
24. Pursuant to Florida law a defendant who, through negligence, causes

significant permanent injury to the natural or adoptive parent of an unmarried dependent

resulting in a permanent total disability shall be liable to the dependent for damages,
including damages for permanent loss of services, comfort, companionship, and society.
25. The Defendant SPT WAH WOODHILL LLC has caused such significant

permanent injury upon Plaintiff MIKEANESHA MOORE and as such RRF, a minor
child is entitled to damages for permanent loss of services, comfort, companionship, and

society.
WHEREFORE, the Plaintiff RMF demands judgment against the Defendant SPT
WAH WOODHILL LLC in excess of the jurisdictional amount for filing in the circuit

court, exclusive of costs and interest, and requests a jury trial.

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 COUNT VI: NEGLIGENCE OF HIGHMARK RESIDENTIAL LLC
26. Plaintiff re-alleges and incorporates herein paragraphs 1-7 and further

alleges:
27. HIGHMARK RESIDENTIAL LLC was the property management

company of the apartment complex located at 7200 Woodhill Park Drive in Orlando,
Florida and managed leased residential dwelling spaces to the public. As the property

manager HIGHMARK RESIDENTIAL LLC had a duty to exercise reasonable care and

protect the Plaintiffs from reasonably foreseeable harm. These duties include providing
the Plaintiffs a safe apartment with safe natural gas connections and appliances free of

gas leaks in adherence to the Florida Statutes, Florida building codes, National Fuel Gas
Code and the Code of Federal Regulations. The Plaintiff HIGHMARK RESIDENTIAL

LLC breached these duties and had actual or constructive notice of these dangers in one

or more of the following ways:

a). Allowing the Plaintiffs to move into an apartment that contained unplugged
and uncapped gas lines and had not been properly inspected for uncapped and unplugged

gas lines;

b). Failing to take reasonably safe precautions after many complaints from tenants
over months and years of gas smells, gas leaks and other evidence of unsafe gas lines
from multiple units in the Woodhill apartment complex;

d). Failing to warn the Plaintiffs and tenants that they had been provided an

apartment that had not been inspected for uncapped and unplugged gas lines;
e). Allowing tenants, employees, agents and other unlicensed gas contractors to
remove gas appliances without capping and plugging gas lines and/or taking other

necessary safety precautions with gas lines and gas appliances;

f). Failing to utilize license gas contractors for all installation, repairs and
maintenance of gas appliances and/or gas lines;

g). Failing to order safety inspection checks for their rental units;
h). Failing to inspect the property and rental units for potential gas leaks,
uncapped gas lines and unplugged gas lines;

i). Failing to meet industry standards, statutes, building and gas codes for the
rental units;

7
 j). Failing to cap and/or plug gas lines after appliances were disconnected by a

previous tenant;
k). Failing to properly notify the Defendant LAKE APOPKA NATURAL GAS
DISTRICT and take appropriate action after complaints from residents about gas smells
and other evidence of gas leaks on the premises;

28. As a direct and proximate result of the negligence of the Defendant

HIGHMARK RESIDENTIAL LLC the Plaintiff MIKEANESHA MOORE suffered

bodily injury resulting in pain and suffering, disability, disfigurement, aggravated a pre-
existing condition or activated a pre-existing condition, mental anguish, loss of the
capacity for the enjoyment of life, medical expenses, travel expenses for medical
treatment, loss of earnings, and loss of the capacity to earn. These losses are either

permanent or continuing in nature, and the Plaintiff will suffer the losses in the future.
WHEREFORE, the Plaintiff MIKEANESHA MOORE demands judgment against
the Defendant HIGHMARK RESIDENTIAL LLC in excess of the jurisdictional amount

for filing in the circuit court, exclusive of costs and interest, and requests a jury trial.

COUNT VII —
LOSS OF CONSORTIUM OF RAVEN FONDIA;
HIGHMARK RESIDENTIAL LLC
29. Plaintiffs re-allege and incorporate herein paragraphs 1-7 and 26-28 and

further allege:
30. At all times material, RAVEN FONDIA was the husband of MIKEANESHA

MOORE and therefore entitled to her care, comfort, support and society.
31. As a direct and proximate result of the Defendant HIGHMARK
RESIDENTIAL LLC's negligence in causing his wife's injury, RAVEN FONDIA has
been permanently deprived of his wife's care, comfort, support and society.

WHEREFORE, the Plaintiff RAVEN FONDIA demands judgment against the

Defendant HIGHMARK RESIDENTIAL LLC in excess of the jurisdictional amount for

filing in the circuit court, exclusive of costs and interest, and requests a jury trial.

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 COUNT VIII- CLAIM OF RRF —
FLORIDA STATUTE 768.0415;
HIGHMARK RESIDENTIAL LLC
32. Plaintiffs as natural parents and guardians on behalf of RRF, a minor, re-

allege and incorporate herein paragraphs 1-7 and 26-28 and further allege:
33. At all times material RRF is a minor child whose name has been redacted for

privacy and was born on 4/2/2010. RRF is an unmarried dependent of MIKEANESHA

MOORE.
34. Pursuant to Florida law a defendant who, through negligence, causes

significant permanent injury to the natural or adoptive parent of an unmarried dependent

resulting in a permanent total disability shall be liable to the dependent for damages,
including damages for permanent loss of services, comfort, companionship, and society.
35. The Defendant HIGHMARK RESIDENTIAL LLC has caused such

significant permanent injury upon Plaintiff MIKEANESHA MOORE and as such RRF, a

minor child is entitled to damages for permanent loss of services, comfort,

companionship, and society.

WHEREFORE, the Plaintiff RRF demands judgment against the Defendant
HIGHMARK RESIDENTIAL LLC in excess of the jurisdictional amount for filing in the
circuit court, exclusive of costs and interest, and requests a jury trial.

COUNT IX- CLAIM OF RLF —

FLORIDA STATUTE 768.0415;
HIGHMARK RESIDENTIAL LLC
36. Plaintiffs as natural parents and guardians on behalf of RLF, a minor, re-allege
and incorporate herein paragraphs 1-7 and 26-28 and further allege:

37. At all times material RLF is a minor child whose name has been redacted for

privacy and was born on 01/01/2015. RLF is an unmarried dependent of MIKEANESHA

MOORE.
38. Pursuant to Florida law a defendant who, through negligence, causes

significant permanent injury to the natural or adoptive parent of an unmarried dependent

resulting in a permanent total disability shall be liable to the dependent for damages,
including damages for permanent loss of services, comfort, companionship, and society.

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 39. The Defendant HIGHMARK RESIDENTIAL LLC has caused such

significant permanent injury upon Plaintiff MIKEANESHA MOORE and as such RLF, a

minor child is entitled to damages for permanent loss of services, comfort,

companionship, and society.

WHEREFORE, the Plaintiff RLF demands judgment against the Defendant
HIGHMARK RESIDENTIAL LLC in excess of the jurisdictional amount for filing in the
circuit court, exclusive of costs and interest, and requests a jury trial.

COUNT X- CLAIM OF RMF —

FLORIDA STATUTE 768.0415;
NEGLIGENCE OF HIGHMARK RESIDENTIAL LLC
40. Plaintiffs as natural parents and guardians on behalf of RMF, a minor, re-

allege and incorporate herein paragraphs 1-7 and 26-28 and further allege:
41. At all times material RMF is a minor child whose name has been redacted for

privacy and was born on 4/10/2019. RMF is an unmarried dependent of MIKEANESHA

MOORE.
42. Pursuant to Florida law a defendant who, through negligence, causes

significant permanent injury to the natural or adoptive parent of an unmarried dependent

resulting in a permanent total disability shall be liable to the dependent for damages,
including damages for permanent loss of services, comfort, companionship, and society.
43. The Defendant HIGHMARK RESIDENTIAL LLC has caused such

significant permanent injury upon Plaintiff MIKEANESHA MOORE and as such RRF, a

minor child is entitled to damages for permanent loss of services, comfort,

companionship, and society.

WHEREFORE, the Plaintiff RMF demands judgment against the Defendant
HIGHMARK RESIDENTIAL LLC in excess of the jurisdictional amount for filing in the
circuit court, exclusive of costs and interest, and requests a jury trial.

10
 COUNT XI: NEGLIGENCE OF LAKE APOPKA NATURAL GAS DISTRICT
44. Plaintiff re-alleges and incorporates herein paragraphs 1-10 and 26-28 and
further alleges:
45. LAKE APOPKA NATURAL GAS DISTRICT is a governmental entity
which owns, operates and maintains natural gas distribution services for the Woodhill

Apartments located at Woodhill Apartments located at 7200 Woodhill Park Drive in

Orlando, Florida. As the utility company that serviced the gas utilities for the residential
units, LAKE APOPKA NATURAL GAS DISTRICT had a duty to exercise reasonable
care and protect the Plaintiff s from reasonably foreseeable harm. The duties include

providing the Plaintiff s with a safe natural gas supply, safe natural gas connections,

proper inspections and investigation of gas leaks, notifying any administrative or

governmental entities of any non-compliance with gas safety protocols and ensuring
compliance to the Florida Statutes, Florida building codes, National Fuel Gas Code and
the Code of Federal Regulations. The Defendant LAKE APOPKA NATURAL GAS

DISTRICT breached these duties and had actual or constructive notice of these dangers
in one or more of the following ways:

a). Knew or should have known of complaints of gas smells from tenants of the

Defendants SPT WAH WOODHILL LLC and HIGHMARK RESIDENTIAL, LLC and
failed to inspect the apartments for uncapped gas lines, unplugged gas lines and other
hazards that are known to cause gas leaks and explosions;

b). When responding to the Woodhill Apartments for out of gas complaints, gas
smell complaints, gas leak complaints, inoperable gas complaints and/or intermittently

operable gas complaints this Defendant failed to adequately inspect the apartments for

uncapped gas lines, unplugged gas lines and other hazards that are known to cause gas
leaks and explosions;

c). Failed to advise and inform the Defendants SPT WAH WOODHILL LLC and
HIGHMARK RESIDENTIAL, LLC of known hazardous conditions on their property

including hazardous gas usage and uncapped and unplugged gas lines from removed gas
appliances;

d) Ignoring and/or failing to use proper procedure for months and years of

complaints from tenants on the Defendants property of gas complaints, gas smell

11
complaints, gas leak complaints, inoperable gas complaints and/or intermittently operable
gas complaints resulting from unplugged and uncapped gas lines from removed

applications.
e). Failing to notify proper entities and report safety violations of the Defendants
SPT WAH WOODHILL LLC and HIGHMARK RESIDENTIAL, LLC.
f). Failing to notify proper entities and report the use of unlicensed gas contractors

by the Defendants SPT WAH WOODHILL LLC and HIGHMARK RESIDENTIAL,

LLC.
46. As a direct and proximate result of the negligence of the Defendant LAKE
APOPKA NATURAL GAS DISTRICT the Plaintiff MIKEANESHA MOORE suffered

bodily injury resulting in pain and suffering, disability, disfigurement, aggravated a pre-
existing condition or activated a pre-existing condition, mental anguish, loss of the
capacity for the enjoyment of life, medical expenses, travel expenses for medical
treatment, loss of earnings, and loss of the capacity to earn. These losses are either

permanent or continuing in nature, and the Plaintiff will suffer the losses in the future.
WHEREFORE, the Plaintiff MIKEANESHA MOORE demands judgment against
the Defendant LAKE APOPKA NATURAL GAS DISTRICT in excess of the

jurisdictional amount for filing in the circuit court, exclusive of costs and interest, and
requests a
jury trial.

COUNT XII —
LOSS OF CONSORTIUM OF RAVEN FONDIA;
LAKE APOPKA NATURAL GAS DISTRICT
47. Plaintiffs re-allege and incorporate herein paragraphs 1-10, 26-28 and 44-46
and further allege:

48. At all times material, RAVEN FONDIA was the husband of MIKEANESHA

MOORE and therefore entitled to her care, comfort, support and society.
49. As a direct and proximate result of the Defendant LAKE APOPKA
NATURAL GAS DISTRICT's negligence in causing his wife's injury, RAVEN
FONDIA has been permanently deprived of his wife's care, comfort, support and society.
WHEREFORE, the Plaintiff RAVEN FONDIA demands judgment against the
Defendant LAKE APOPKA NATURAL GAS DISTRICT in excess of the jurisdictional

12
amount for filing in the circuit court, exclusive of costs and interest, and requests a jury
trial.

COUNT XIII- CLAIM OF RRF —

FLORIDA STATUTE 768.0415;
LAKE APOPKA NATURAL GAS DISTRICT
50. Plaintiffs as natural parents and guardians on behalf of RRF, a minor, re-

allege and incorporate herein paragraphs 1-10, 26-28 and 44-46 and further allege:
51. At all times material RRF is a minor child whose name has been redacted for

privacy and was born on 4/2/2010. RRF is an unmarried dependent of MIKEANESHA

MOORE.
52. Pursuant to Florida law a defendant who, through negligence, causes

significant permanent injury to the natural or adoptive parent of an unmarried dependent

resulting in a permanent total disability shall be liable to the dependent for damages,
including damages for permanent loss of services, comfort, companionship, and society.
53. The Defendant LAKE APOPKA NATURAL GAS DISTRICT has caused
such significant permanent injury upon Plaintiff MIKEANESHA MOORE and as such

RRF, a minor child is entitled to damages for permanent loss of services, comfort,

companionship, and society.

WHEREFORE, the Plaintiff RRF demands judgment against the Defendant
LAKE APOPKA NATURAL GAS DISTRICT in excess of the jurisdictional amount for

filing in the circuit court, exclusive of costs and interest, and requests a jury trial.

COUNT XIV- CLAIM OF RLF —

FLORIDA STATUTE 768.0415;
LAKE APOPKA NATURAL GAS DISTRICT
54. Plaintiffs as natural parents and guardians on behalf of RLF, a minor, re-allege
and incorporate herein paragraphs 1-10, 26-28 and 44-46 and further allege:

55. At all times material RLF is a minor child whose name has been redacted for

privacy and was born on 01/01/2015. RLF is an unmarried dependent of MIKEANESHA

MOORE.
56. Pursuant to Florida law a defendant who, through negligence, causes

significant permanent injury to the natural or adoptive parent of an unmarried dependent

13
resulting in a permanent total disability shall be liable to the dependent for damages,
including damages for permanent loss of services, comfort, companionship, and society.
57. The Defendant LAKE APOPKA NATURAL GAS DISTRICT has caused
such significant permanent injury upon Plaintiff MIKEANESHA MOORE and as such

RLF, a minor child is entitled to damages for permanent loss of services, comfort,

companionship, and society.

WHEREFORE, the Plaintiff RLF demands judgment against the Defendant
LAKE APOPKA NATURAL GAS DISTRICT in excess of the jurisdictional amount for

filing in the circuit court, exclusive of costs and interest, and requests a jury trial.

COUNT XV- CLAIM OF RMF —

FLORIDA STATUTE 768.0415;
NEGLIGENCE OF LAKE APOPKA GAS DISTRICT
58. Plaintiffs as natural parents and guardians on behalf of RMF, a minor, re-

allege and incorporate herein paragraphs 1-10, 26-28 and 44-46 and further allege:
59. At all times material RMF is a minor child whose name has been redacted for

privacy and was born on 4/10/2019. RMF is an unmarried dependent of MIKEANESHA

MOORE.
60. Pursuant to Florida law a defendant who, through negligence, causes

significant permanent injury to the natural or

adoptive parent of an unmarried dependent

resulting in a permanent total disability shall be liable to the dependent for damages,
including damages for permanent loss of services, comfort, companionship, and society.
61. The Defendant LAKE APOPKA NATURAL GAS DISTRICT has caused
such significant permanent injury upon Plaintiff MIKEANESHA MOORE and as such

RRF, a minor child is entitled to damages for permanent loss of services, comfort,
companionship, and society.
WHEREFORE, the Plaintiff RMF demands judgment against the Defendant
LAKE APOPKA NATURAL GAS DISTRICT in excess of the jurisdictional amount for

filing in the circuit court, exclusive of costs and interest, and requests a jury trial.

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 DATED and FILED in the Circuit Court of Orange County, FL this 8th day of

March, 2024.

/s/ Richard B. Troutman

RICHARD B. TROUTMAN, Esquire
Florida Bar No. 306347
MATTHEW R. BOREN, Esquire
Florida Bar No. 718505
The Troutman Law Firm
1101 North Kentucky Avenue
Winter Park, Florida 32789
(T): 407-647-5002
Attorneys for Plaintiffs
Primary: rick@richardtroutman.com
nleadings@richardtroutman.com
matthewboren@matthewboren.com

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