05
Case File
The case file contains 9 documents — witness statements and exhibits. Work only from these materials and from what you develop in your interviews.
WITNESS STATEMENT · STATEMENT REYES
Witness Statement — Sofia Reyes
Signed statement given to counsel, Ellingboe & Ravndal LLP. Sunhaven County, Florida.
My name is Sofia Reyes. I am thirty-four years old and I live in Belmar Springs. I drive for a rideshare app full time — it is how I pay my bills. On a normal week I do somewhere between fifty and sixty trips. I have been doing it for about three years and I have a clean driving record.
On Thursday, February 6, 2025, I was working the early-evening shift. I had picked up a passenger a few minutes earlier and was heading west on Camino Real Boulevard. It was right around ten of six. The sky was clear but the sun was low and right in my eyes, so I had my visor down and I was driving carefully. I would say I was going about 25, which is under the limit there. I do not speed with a passenger in the car.
As I came up to the light at 22nd Avenue it was green. I remember it being green because I checked, the way I always do at that intersection — it is a busy one. I started through the intersection and the next thing I knew there was a huge SUV turning left right into me. I did not even have time to hit the brakes hard. He hit my passenger side and my car spun around. Both my airbags went off. My knee slammed into something under the dash. When the car stopped I was facing the wrong direction, halfway into the crosswalk.
I could not put any weight on my right knee. The pain was unbelievable. Somebody called 911 and the ambulance took me to the hospital. The X-ray did not show a break, so they put me in a brace and told me to see a knee specialist. Later I got an MRI and it turned out I had a torn meniscus. I had surgery on March 18 and then about ten weeks of physical therapy. I could not drive for the app that whole time, so I had no income coming in.
The officer at the scene talked to me, to the other driver, and to a man who saw the whole thing from the other street. She gave the other driver a ticket, not me. I know I had the green. He turned left across my lane and never gave me a chance.
The bills have been crushing. My own insurance paid a little under my PIP but it ran out fast, and then they dragged their feet on the rest. My car was totaled. I got behind on my rent during the weeks I could not work, and I am still trying to catch up. I just want this made right.
WITNESS STATEMENT · STATEMENT HUTCHINS
Witness Statement — Bradley Hutchins
Recorded statement summary, taken by the defense liability carrier and produced in discovery. Sunhaven County, Florida.
My name is Bradley Hutchins. I am forty-one. I work as a regional sales rep and I drive a lot for my job. I live a couple of towns over from Belmar Springs but I go through it every day on my commute. I drive a full-size SUV.
On February 6, 2025, I was on my way home after a client meeting that ran late. It had been a long day. I was heading east on Camino Real Boulevard and I needed to make a left onto 22nd Avenue to cut over toward the highway. I pulled into the left-turn lane when my light was green. There was oncoming traffic, so I edged out into the intersection and waited for a gap, the way you are supposed to.
The light turned yellow. I looked and I thought the westbound car coming at me had plenty of room to stop for the yellow. I started my turn. The next thing I know that car is right there and I could not stop the turn in time. My front end caught the side of the sedan. I honestly believe that car sped up to beat the light instead of stopping, and by the time it went through it was already yellow, going to red, against them.
I got out to check on the other driver. She was hurt and shaken and I felt terrible about that, I really did. But I do not think this was all on me. I had committed to the turn on a yellow and I expected the oncoming car to stop. The officer gave me a ticket for failure to yield, which I do not think is fair given that the other driver ran a stale light.
There was another driver stopped on the side street who talked to the officer. I do not know what he told her. My insurance company is handling the claim and I have turned it all over to them and to the lawyer they gave me.
WITNESS STATEMENT · STATEMENT FONTAINE
Witness Statement — Gerald Fontaine (Independent Eyewitness)
Signed statement. Sunhaven County, Florida.
My name is Gerald Fontaine. I am fifty-two and I live in Belmar Springs. I do not know either of the drivers in this accident and I have no stake in what happens. I just happened to be there and I saw it.
On the evening of February 6, 2025, I was stopped in the left-turn lane on 22nd Avenue, waiting to turn. I was facing the intersection, so I had a straight-on view of both the traffic light for Camino Real Boulevard and the cars going through it. It was clear out but the sun was going down.
The light for Camino Real — the through traffic on the boulevard — was green. I am sure of that because I was watching it, waiting for my own arrow. I saw a westbound sedan coming through the intersection with the green. At the same time an SUV heading the other direction, eastbound, started making a left turn right across in front of the sedan. The SUV just went. The sedan had no chance. The SUV hit the side of the sedan and spun it clear around.
To me it looked like the sedan had the right of way and was going a normal speed — nothing crazy, not racing to beat anything. The SUV turned left when it should have yielded. I did not see the sedan try to run any light. When the light in front of the boulevard was green, that meant it was green for the sedan going straight.
I pulled over, made sure I was out of the way, and gave my name and phone number to the police officer who came. I told her the same thing I am writing here. I am willing to say it again if I need to.
CASE-FILE DOCUMENT · CRASH REPORT
Exhibit m13.exh.001 — Florida Traffic Crash Report
Agency: Belmar Springs Police Department Report No.: BSPD-2025-0207-114 Investigating Officer: Officer Elaine Sturdivant, Badge 4417 Date/Time of Crash: February 6, 2025, approx. 1750 hours Location: Intersection of Camino Real Boulevard and 22nd Avenue, Belmar Springs, Sunhaven County, FL
Conditions
- Weather: Clear
- Roadway surface: Dry
- Light: Daylight/dusk; low sun on the western horizon
- Contributing environmental condition noted: sun glare for westbound traffic
Vehicles
- Vehicle 1 (V1): 2019 four-door sedan. Driver: Sofia Reyes. Direction: westbound on Camino Real Blvd, proceeding straight. Occupied by driver and one passenger.
- Vehicle 2 (V2): Late-model full-size SUV. Driver: Bradley Hutchins. Direction: eastbound on Camino Real Blvd, turning left onto northbound 22nd Ave.
Narrative
V1 was traveling westbound through the intersection. V2, traveling eastbound, was executing a left turn onto 22nd Avenue. The front of V2 struck the right (passenger) side of V1 within the intersection. Impact rotated V1 approximately 90 degrees and displaced it into the northern crosswalk. Both frontal airbags in V1 deployed.
Driver of V1 stated she entered on a green through-signal at approximately 25 mph. Driver of V2 stated he entered on green, waited for a gap, and began his left turn as the signal changed to yellow, expecting V1 to stop.
An independent witness, Gerald Fontaine, stopped in the northbound left-turn lane of 22nd Avenue, reported that the Camino Real through-signal was green and that V2 turned left across the path of V1. Physical evidence (point of impact, debris field, final rest positions) is consistent with V1 proceeding straight through the intersection and V2 turning left into V1.
Injuries
Driver of V1 reported right-knee pain and was unable to bear weight; transported by ambulance to the emergency department. Driver of V2 reported no injury. Passenger in V1 reported no injury.
Enforcement Action
Citation issued to driver of V2 (Bradley Hutchins) for failure to yield right of way while turning left. No citation issued to driver of V1.
This intersection is not equipped with a red-light enforcement camera; no automated video is available.
Officer Elaine Sturdivant, Belmar Springs PD.
CASE-FILE DOCUMENT · MEDICAL RECORDS
Exhibit m13.exh.003 — Emergency Department and Operative Medical Records (Summary)
Patient: Sofia Reyes, DOB redacted (age 34) Treating orthopedic surgeon: Dr. Nadia Emerson, Belmar Springs Orthopedic Associates
Emergency Department — February 6, 2025
Patient arrived by ambulance following a motor-vehicle collision. Chief complaint: severe right-knee pain, unable to bear weight. Examination: swelling and tenderness of the right knee; limited range of motion; neurovascularly intact. Plain radiographs of the right knee showed no acute fracture. Diagnosis: acute right-knee internal derangement, rule out meniscal/ligamentous injury. Discharged with knee immobilizer, crutches, analgesia, and referral to orthopedics.
MRI — February 20, 2025
MRI of the right knee demonstrated a tear of the medial meniscus. Mild degenerative signal noted; no ligament rupture.
Operative Report — March 18, 2025
Procedure: right-knee diagnostic arthroscopy with meniscal repair, performed by Dr. Emerson. Findings: tear of the medial meniscus consistent with an acute traumatic mechanism, with some background degenerative change. Repair completed without complication. Patient tolerated the procedure well.
Physical Therapy — late March through early June 2025
Approximately ten weeks of supervised physical therapy, progressing from immobilization to weight-bearing and strengthening.
Treating-Physician Narrative (Dr. Emerson)
It is my opinion that the medial meniscus tear is consistent with the mechanism of the February 6, 2025 collision. The patient reported a history of intermittent left-knee soreness from a prior recreational injury; the acute injury here involves the right knee. In my opinion the patient has reached maximum medical improvement with a permanent partial impairment of the right knee and an increased long-term risk of post-traumatic arthritis in that knee.
Billing Summary
Emergency department, imaging, surgical, anesthesia, facility, and physical-therapy charges total approximately $42,000.
Records summarized for the case file; full records retained by counsel.
CASE-FILE DOCUMENT · RIDESHARE EARNINGS
Exhibit m13.exh.004 — Rideshare Earnings Statements (Summary)
Driver: Sofia Reyes Platform: Rideshare passenger-transport platform (name withheld) Prepared for: Lost-income documentation
Pre-Crash Weekly Net Earnings (representative 12-week period, Nov 2024 – Jan 2025)
| Week ending | Trips | Net earnings |
|---|
| 2024-11-24 | 57 | $872 |
| 2024-12-01 | 54 | $831 |
| 2024-12-08 | 59 | $905 |
| 2024-12-15 | 52 | $798 |
| 2024-12-22 | 61 | $940 |
| 2025-01-05 | 48 | $742 |
| 2025-01-12 | 55 | $846 |
| 2025-01-19 | 58 | $889 |
| 2025-01-26 | 53 | $818 |
| 2025-02-02 | 56 | $861 |
Average pre-crash weekly net earnings: approximately $850.
Post-Crash Earnings
Following the February 6, 2025 collision and subsequent surgery on March 18, 2025, the driver was medically unable to work for approximately ten weeks (early February through mid-April 2025), with a graduated return through early June. Trip activity during the off-work period was zero.
Estimated lost income for the ten-week off-work period: approximately $8,500 (10 weeks × ~$850/week).
Underlying weekly statements retained by counsel.
CASE-FILE DOCUMENT · PIP CORRESPONDENCE
Exhibit m13.exh.005 — PIP / No-Fault Insurance Correspondence Log
Insured/Claimant: Sofia Reyes Coverage: Personal Injury Protection (PIP) under claimant's own auto policy PIP limit: $10,000
| Date | Event |
|---|
| 2025-02-10 | Claimant reports the crash to her own auto insurer and opens a PIP claim; initial medical bills submitted. |
| 2025-02-24 | Insurer acknowledges claim; requests additional documentation (MRI report, provider records, wage verification) before processing lost-wage component. |
| 2025-03-14 | Insurer pays initial medical benefits; claimant advised PIP is subject to the $10,000 aggregate limit. |
| 2025-04-08 | Claimant submits wage-loss documentation (rideshare earnings statements). Insurer requests further verification of self-employment income, delaying the wage-loss payment. |
| 2025-05-02 | PIP benefits exhausted at the $10,000 limit; a fraction of the ~$42,000 in medical bills is covered. Remaining medical expenses, wage loss beyond the PIP cap, and all non-economic damages fall outside PIP. |
| 2025-05-20 | Claimant notified that further medical expenses will not be paid under PIP; balance of bills outstanding to providers. |
Notes for the file
- Under Florida's no-fault framework, the claimant's own PIP coverage is the first payer for medical and a portion of lost wages, up to the policy limit, regardless of fault.
- PIP was exhausted quickly given the size of the medical bills, leaving the great majority of medical expenses and all pain-and-suffering damages uncovered by PIP.
- Whether the claimant may pursue the at-fault driver directly for the remaining damages depends on whether her injury clears the statutory injury threshold — a legal question for counsel to research and analyze.
- The initial delay in processing the wage-loss component added to the claimant's financial stress during her time off work.
Correspondence log maintained by counsel.
CASE-FILE DOCUMENT · PROPERTY DAMAGE
Exhibit m13.exh.006 — Property-Damage Estimate and Total-Loss Valuation
Vehicle: 2019 four-door sedan Owner: Sofia Reyes Assessed by: Claimant's auto insurer, property-damage unit
Damage Description
Impact to the right (passenger) side: crushed right front fender, right front and rear passenger doors, deformed B-pillar, and frame intrusion into the passenger compartment. Both frontal airbags deployed. Right front wheel and suspension displaced. Vehicle rotated approximately 90 degrees on impact.
Repair Estimate
Estimated repair cost: approximately $9,800, including structural, body, airbag-module, and mechanical repairs.
Valuation and Disposition
Pre-loss actual cash value of the vehicle was assessed at approximately $8,600. Because the estimated repair cost exceeded the vehicle's value, the insurer declared the vehicle a total loss. The claimant owned the vehicle free of any lien.
Scene Photographs (described)
The file includes scene and vehicle photographs showing:
- The final rest position of the sedan angled into the northern crosswalk.
- Broadside crush and door intrusion on the passenger side of the sedan.
- Front-end damage to the SUV consistent with striking the side of the sedan.
- The intersection signal heads and lane markings, showing dedicated left-turn lanes on Camino Real Boulevard and the westbound approach into the setting sun.
- Debris field and skid/gouge marks within the intersection.
Estimate and photographs retained by counsel.
CASE-FILE DOCUMENT · DEMAND LETTER
Exhibit m13.exh.007 — Settlement Demand Letter to Liability Insurer
From: Ellingboe & Ravndal LLP, counsel for Sofia Reyes To: Claims Department, liability insurer for Bradley Hutchins Date: October 20, 2025 Re: Reyes v. Hutchins — collision of February 6, 2025
To the Claims Adjuster:
This firm represents Sofia Reyes for injuries and damages arising from the February 6, 2025 collision at Camino Real Boulevard and 22nd Avenue in Belmar Springs. This letter presents our client's demand.
Liability. Your insured, Mr. Hutchins, turned left across the path of Ms. Reyes, who was proceeding straight through the intersection on a green signal. An independent eyewitness with no relationship to either driver confirms that the through-signal was green and that your insured turned left without yielding. The investigating officer issued your insured a citation for failure to yield. Liability rests with your insured.
Injuries and treatment. Ms. Reyes sustained a torn medial meniscus of the right knee requiring arthroscopic surgery on March 18, 2025, followed by roughly ten weeks of physical therapy. Her treating surgeon assesses a permanent partial impairment of the knee and an increased risk of future arthritis.
Damages. Medical expenses total approximately $42,000. Lost income for the ten weeks Ms. Reyes could not work totals approximately $8,500. Her vehicle was a total loss with roughly $9,800 in damage. These economic losses stand alongside her past and future pain, suffering, and loss of enjoyment of life.
Based on the clear liability and the seriousness and permanence of the injury, we demand settlement in an amount that fully and fairly compensates Ms. Reyes. We are prepared to document each element of damage. We look forward to your prompt response.
Very truly yours, Ellingboe & Ravndal LLP
Carrier's response (summarized for the file): The liability insurer responded with a low offer, asserting that Ms. Reyes bears a substantial share of comparative fault for allegedly entering on a late signal while distracted, and disputing the permanency of the injury in light of the noted prior knee history.
06
Procedural and Factual History
On February 6, 2025, at approximately 5:50 p.m., Sofia Reyes was driving westbound through the intersection of Camino Real Boulevard and 22nd Avenue in Belmar Springs when Bradley Hutchins, turning left in his SUV, struck the passenger side of her sedan. The setting sun produced glare for westbound drivers, and the two drivers disagree about the state of the traffic signal at the moment they entered the intersection. The investigating officer, relying on the physical evidence and an independent eyewitness, cited Mr. Hutchins for failure to yield. Ms. Reyes was hospitalized, later diagnosed with a torn medial meniscus, and underwent arthroscopic surgery on March 18, 2025, followed by about ten weeks of physical therapy during which she could not work.
Ms. Reyes first submitted her medical bills and lost wages to her own insurer under Florida's no-fault PIP coverage, which was quickly exhausted at its $10,000 limit. She retained Ellingboe & Ravndal LLP on a contingency basis in March 2025. The firm filed a negligence complaint against Mr. Hutchins in the Circuit Court for Sunhaven County. Mr. Hutchins, defended by counsel through his liability insurer, answered and raised comparative fault, alleging that Ms. Reyes ran a late signal and was distracted. The parties are now in written discovery, with depositions of the drivers and the eyewitness being scheduled. A settlement demand drew a low offer premised on shared fault. The matter is being prepared for a civil jury trial.
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Substantive Information
This exercise sits in the law of negligence as applied to motor-vehicle collisions, overlaid with Florida's no-fault automobile-insurance system. You are expected to research the controlling Florida authorities yourself; the following is a neutral map of the terrain, not a statement of the law.
Negligence. A motor-vehicle negligence claim requires a duty of care, a breach of that duty, causation, and damages. Here, breach centers on which driver violated the rules of the road at the intersection — the driver turning left across oncoming traffic, or a driver who allegedly entered against a signal. Causation and damages are documented through the medical and economic records, subject to the defense's argument that some of the knee condition predates the crash.
Comparative fault. Florida allocates fault among the parties, and a plaintiff's own share of fault affects recovery. You should research the current form of Florida's comparative-fault regime and any threshold at which a plaintiff's share bars recovery, and consider how it applies to the disputed entry into the intersection and the alleged distraction.
No-fault / Personal Injury Protection. Florida's motor-vehicle framework requires drivers to carry PIP coverage that pays a portion of medical expenses and lost wages regardless of fault, up to a policy limit. The system limits when an injured person may step outside no-fault to sue the at-fault driver for pain and suffering, generally requiring that the injury meet a statutory threshold of seriousness or permanence. The treating surgeon's permanency assessment is therefore doubly important: it supports both the damages claim and the gateway to a direct suit.
Damages. Economic damages include past and future medical expenses, lost income, and property damage. Non-economic damages include past and future pain, suffering, and loss of enjoyment of life, available if the injury clears the threshold. Research how future medical needs and the increased arthritis risk factor into a Florida damages presentation.
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Business of the matter
Every matter carries its business layer — the engagement, the clock, and (where client
funds are held) the trust ledger. The firm
dashboard aggregates all twenty.
BUSINESS EXHIBIT · ENGAGEMENT LETTER
Contingency-Fee Engagement Letter
Ellingboe & Ravndal LLP 310 Riverwalk Plaza, Suite 400, Norsholm, Meridian 55901
Date: March 8, 2025
Client: Sofia Reyes 48 Palmetto Row, Belmar Springs, FL
Re: Personal-injury claim arising from the motor-vehicle collision of February 6, 2025
Dear Ms. Reyes:
Thank you for choosing Ellingboe & Ravndal LLP. This letter sets out the terms of our engagement.
Scope of representation. You are retaining the firm to represent you in your claim for personal injuries, medical expenses, lost income, and property damage arising from the February 6, 2025 collision at Camino Real Boulevard and 22nd Avenue in Belmar Springs, Florida, including any negotiation, litigation in the Circuit Court, and trial the matter requires. This engagement does not include any appeal or any unrelated matter, which would be the subject of a separate agreement.
Our fee — contingency. Because this is a personal-injury matter, we are handling it on a contingency-fee basis. This means you pay no attorney's fee unless we obtain a recovery for you by settlement, judgment, or award. Our fee will be a percentage of the gross recovery, calculated on a tiered basis consistent with the Florida Bar's rules governing contingency fees in personal-injury cases: the percentage is lower for a recovery obtained before a lawsuit is filed and higher once suit is filed and the case is litigated, with further adjustment if the matter is appealed. The specific tiers and percentages are set out in the accompanying statement of client rights, which you acknowledge receiving. If there is no recovery, you owe us no attorney's fee.
Costs and expenses. The firm will advance the out-of-pocket costs of pursuing your case — such as the filing fee, records charges, deposition costs, and expert fees. These advanced costs are separate from the attorney's fee and will be reimbursed to the firm from your share of any recovery. If there is no recovery, we will not seek reimbursement of advanced costs from you personally.
No guarantee of outcome. We will pursue your case diligently, but we cannot and do not guarantee any particular result. The other driver disputes fault and has raised a comparative-fault defense, and Florida's no-fault insurance system affects how your claim proceeds; we will keep you informed as the case develops.
Your role. Please keep us informed of any change in your treatment, your address, or your circumstances, preserve any evidence, and direct any contact from the other driver or his insurer to us.
If these terms are acceptable, please sign below and return a copy.
Sincerely,
Amara Ellingboe Ellingboe & Ravndal LLP
Agreed and accepted:
________________________________ Date: ____________ Sofia Reyes
BUSINESS EXHIBIT · INTAKE & CONFLICTS
Intake (2025-03-05). Rideshare driver injured in an intersection collision seeks to recover from the at-fault left-turning driver; torn meniscus with surgery, lost income, totaled vehicle, and an exhausted PIP layer. Contingency representation toward a civil jury trial.
Conflicts check (2025-03-06) — CLEAR. No prior or current representation adverse to Sofia Reyes; the firm has never represented Bradley Hutchins or his liability insurer. No relationship to the independent eyewitness.
BUSINESS EXHIBIT · BILLING STATEMENT (11 TIME ENTRIES)
Contingency engagement — time is recorded to show effort invested; the fee is a percentage of recovery, not these amounts.
| Date | TK | Narrative | Hours | Rate | Amount |
|---|
| 2025-03-05 | FIRM-TK-01 | Initial intake interview with client; preliminary assessment of liability and injuries. | 1.5 | $250 | $375.00 |
| 2025-03-06 | FIRM-TK-02 | Run conflicts check; open matter; prepare contingency engagement letter. | 0.8 | $225 | $180.00 |
| 2025-03-12 | FIRM-TK-02 | Review Florida crash report and emergency/operative medical records; build chronology of the collision and treatment. | 2.3 | $225 | $517.50 |
| 2025-03-20 | FIRM-TK-01 | Interview independent eyewitness Gerald Fontaine; obtain signed statement. | 1.2 | $250 | $300.00 |
| 2025-04-02 | FIRM-TK-02 | Obtain and review PIP correspondence; analyze no-fault threshold and coverage-exhaustion issues. | 1.7 | $225 | $382.50 |
| 2025-05-15 | FIRM-TK-02 | Draft and file negligence complaint in the Circuit Court for Sunhaven County. | 2.0 | $225 | $450.00 |
| 2025-07-10 | FIRM-TK-01 | Client counseling regarding comparative-fault exposure and settlement posture. | 1.4 | $250 | $350.00 |
| 2025-10-18 | FIRM-TK-02 | Prepare and send settlement demand to the liability insurer; assemble damages documentation. | 1.9 | $225 | $427.50 |
| 2026-01-22 | FIRM-TK-02 | Draft written discovery: interrogatories and requests for production to the defendant. | 2.6 | $225 | $585.00 |
| 2026-04-15 | FIRM-TK-01 | Prepare for depositions of the two drivers and the independent eyewitness. | 1.1 | $250 | $275.00 |
| 2026-06-12 | FIRM-TK-02 | Trial preparation: exhibit organization, intersection diagram, and witness planning. | 1.5 | $225 | $337.50 |
| Total | | | 18.0 | | $4,180.00 |
Instructor materials (master fact pattern, teaching notes, answer
guidance) are maintained separately and are not part of the student packet.
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