Filing # 230867015 E-Filed 09/04/2025 02:54:14 PM
`
`IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
`IN AND FOR ORANGE COUNTY, FLORIDA
`
`CASE NO:
`
`SARA THOMAS-GONCALVES,
`
`Plaintiff,
`Vvs.
`SPECIALTY DISTRIBUTION
`GROUP, LLC and MICHAEL
`LARSON,
`
`Defendants. /
`
`COMPLAINT
`
`COMES NOW, Plaintiff, SARA THOMAS-GONCALVES, sues Defendants, SPECIALTY
`DISTRIBUTION GROUP, LLC and MICHAEL LARSON, and alleges:
`
`1. This is an action for damages that exceeds the sum of FIFTY THOUSAND DOLLARS
`($50,000.00), exclusive of costs, interest and attorneys’ fees (The estimated value of
`Plaintiff’s claim is in excess of the minimum jurisdictional threshold required by this
`Court). Accordingly, Plaintiff has entered “$50,001” in the civil cover sheet for the
`“estimated amount of the claim” as required in the preamble to the civil cover sheet for
`Jurisdictional purposes only (the Florida Supreme Court has ordered that the estimated
`“amount of claim” be set forth in the civil cover sheet for data collection and clerical purposes
`only). The actual value of Plaintiff’s claim will be determined by a fair and just jury in
`
`accordance with Article 1, Section 21, Fla. Const.
`
`
`
`
`
`
`
`
`10.
`
`At all times material to this action, Plaintiff was a natural person residing in St. John’s County,
`Florida.
`
`At all times material to this action, Defendant, MICHAEL LARSON, was a natural person
`residing in Wildwood, Sumter County, Florida.
`
`At all times material hereto, Defendant, SPECIALTY DISTRIBUTION GROUP, LLC, was
`authorized, licensed and actually conducting business in the State of Florida.
`
`On or about April 21, 2025, Plaintiff was a passenger in a motor vehicle traveling at or near
`Interstate 4 and State Road 535 in Orlando, Orange County, Florida.
`
`At that time and place, Defendant, MICHAEL LARSON, was operating a motor vehicle
`traveling owned by Defendant, SPECIALTY DISTRIBUTION GROUP, LLC, traveling at
`or near Interstate 4 and State Road 535 in Orlando, Orange County, Florida.
`
`Defendant, MICHAEL LARSON, was operating and driving the motor vehicle with the
`permission and consent of its owner, Defendant, SPECIALTY DISTRIBUTION GROUP,
`LLC.
`
`At that time and place, Defendant, MICHAEL LARSON negligently operated and/or
`maintained the motor vehicle so that it caused an impact with Plaintiff's motor vehicle.
`Venue is proper in Orange County because the subject car collision occurred in Orange
`County, Florida.
`
`COUNT I - CLAIM OF NEGLIGENCE AGAINST DEFENDANT, MICHAEL
`LARSON
`
`Plaintiff, adopts, realleges those allegations contained within paragraphs 1-9, above and
`
`incorporates them herein by reference, and further states:
`
`
`
`
`
`
`
`
`11. On or about April 21, 2025, Plaintiff was a passenger in a motor vehicle traveling at or near
`Interstate 4 and State Road 535 in Orlando, Orange County, Florida.
`
`12. At that time and place, Defendant, MICHAEL LARSON, was operating a motor vehicle
`traveling owned by Defendant, SPECIALTY DISTRIBUTION GROUP, LLCDefendant,
`MICHAEL LARSON, was operating and driving the motor vehicle with the permission and
`consent of its owner, Defendant, SPECIALTY DISTRIBUTION GROUP, LLC.
`
`13. At that time and place, Defendant, MICHAEL LARSON negligently operated and/or
`maintained the motor vehicle so that it caused an impact with Plaintiff's motor vehicle.
`
`14. As a direct and proximate result of Defendants’ negligence, Plaintiff 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.
`
`15. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future.
`Plaintiff's motor vehicle was also damaged.
`
`WHEREFORE, Plaintiff, SARA THOMAS-GONCALVES, demands judgment for
`damages against Defendants MICHAEL LARSON, and other such relief deemed proper by the
`Court.
`
`COUNT IT - CLAIM OF NEGLIGENCE AGAINST DEFENDANT, SPECIALTY
`DISTRIBUTION GROUP, LLC
`
`16. Plaintiff, adopts, realleges those allegations contained within paragraphs 1-16, above and
`
`incorporates them herein by reference, and further states:
`
`
`
`
`
`
`
`
`17.
`
`18.
`
`19.
`
`20.
`
`21.
`
`22.
`
`On or about April 21, 2025, Plaintiff was a passenger in a motor vehicle traveling at or near
`Interstate 4 and State Road 535 in Orlando, Orange County, Florida.
`
`At that time and place, Defendant, MICHAEL LARSON, was operating a motor vehicle
`traveling owned by Defendant, SPECIALTY DISTRIBUTION GROUP, LLCDefendant,
`MICHAEL LARSON, was operating and driving the motor vehicle with the permission and
`consent of its owner, Defendant, SPECIALTY DISTRIBUTION GROUP, LLC.
`
`At that time and place, Defendant, MICHAEL LARSON negligently operated and/or
`maintained the motor vehicle so that it caused an impact with Plaintiff's motor vehicle.
`Defendant, SPECIALTY DISTRIBUTION GROUP, LLC, is vicariously liable for the
`negligence of Defendant, MICHAEL LARSON, pursuant to the Florida Dangerous
`Instrumentality Doctrine because Defendant, SPECIALTY DISTRIBUTION GROUP, LLC,
`owned the vehicle operated by Defendant, MICHAEL LARSON, at the time of the subject
`car collision.
`
`Defendant, SPECIALTY DISTRIBUTION GROUP, LLC, is vicariously liable for the
`negligence of Defendant, MICHAEL LARSON, pursuant to the doctrine of Respondeat
`Superior, because Defendant, MICHAEL LARSON, was in the course and scope of his
`employment with Defendant, SPECIALTY DISTRIBUTION GROUP, LLC, at the time of
`the subject car collision.
`
`As a direct and proximate result of Defendants’ negligence, Plaintiff 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.
`23. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future.
`Plaintiff's motor vehicle was also damaged.
`WHEREFORE, Plaintiff; SARA THOMAS-GONCALVES, demands judgment for
`damages against Defendants SPECIALTY DISTRIBUTION GROUP, LLC, and other such relief
`deemed proper by the Court.
`
`DEMAND FOR JURY TRIAL
`
`Plaintiff also demands a jury trial on all issues so triable.
`
`RESPECTFULLY submitted this 4th day of September, 2025.
`
`Stephen Lynch,
`
`FBN: 1024807
`
`Morgan & Morgan, P.A.
`
`20 N. Orange Avenue
`
`Suite 1600
`
`Orlando, FL 32801
`
`Telephone: (689) 219-2085
`
`Facsimile: (689) 219-2185
`
`Primary email: slynch@forthepeople.com
`Secondary email: cmolina@forthepeople.com
`Attorney for Plaintiff
`
`
`
`
`
`
`
`
`
`
`
`IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
`IN AND FOR ORANGE COUNTY, FLORIDA
`
`CASE NO:
`
`SARA THOMAS-GONCALVES,
`
`Plaintiff,
`Vvs.
`SPECIALTY DISTRIBUTION
`GROUP, LLC and MICHAEL
`LARSON,
`
`Defendants. /
`
`COMPLAINT
`
`COMES NOW, Plaintiff, SARA THOMAS-GONCALVES, sues Defendants, SPECIALTY
`DISTRIBUTION GROUP, LLC and MICHAEL LARSON, and alleges:
`
`1. This is an action for damages that exceeds the sum of FIFTY THOUSAND DOLLARS
`($50,000.00), exclusive of costs, interest and attorneys’ fees (The estimated value of
`Plaintiff’s claim is in excess of the minimum jurisdictional threshold required by this
`Court). Accordingly, Plaintiff has entered “$50,001” in the civil cover sheet for the
`“estimated amount of the claim” as required in the preamble to the civil cover sheet for
`Jurisdictional purposes only (the Florida Supreme Court has ordered that the estimated
`“amount of claim” be set forth in the civil cover sheet for data collection and clerical purposes
`only). The actual value of Plaintiff’s claim will be determined by a fair and just jury in
`
`accordance with Article 1, Section 21, Fla. Const.
`
`
`
`
`
`
`
`
`10.
`
`At all times material to this action, Plaintiff was a natural person residing in St. John’s County,
`Florida.
`
`At all times material to this action, Defendant, MICHAEL LARSON, was a natural person
`residing in Wildwood, Sumter County, Florida.
`
`At all times material hereto, Defendant, SPECIALTY DISTRIBUTION GROUP, LLC, was
`authorized, licensed and actually conducting business in the State of Florida.
`
`On or about April 21, 2025, Plaintiff was a passenger in a motor vehicle traveling at or near
`Interstate 4 and State Road 535 in Orlando, Orange County, Florida.
`
`At that time and place, Defendant, MICHAEL LARSON, was operating a motor vehicle
`traveling owned by Defendant, SPECIALTY DISTRIBUTION GROUP, LLC, traveling at
`or near Interstate 4 and State Road 535 in Orlando, Orange County, Florida.
`
`Defendant, MICHAEL LARSON, was operating and driving the motor vehicle with the
`permission and consent of its owner, Defendant, SPECIALTY DISTRIBUTION GROUP,
`LLC.
`
`At that time and place, Defendant, MICHAEL LARSON negligently operated and/or
`maintained the motor vehicle so that it caused an impact with Plaintiff's motor vehicle.
`Venue is proper in Orange County because the subject car collision occurred in Orange
`County, Florida.
`
`COUNT I - CLAIM OF NEGLIGENCE AGAINST DEFENDANT, MICHAEL
`LARSON
`
`Plaintiff, adopts, realleges those allegations contained within paragraphs 1-9, above and
`
`incorporates them herein by reference, and further states:
`
`
`
`
`
`
`
`
`11. On or about April 21, 2025, Plaintiff was a passenger in a motor vehicle traveling at or near
`Interstate 4 and State Road 535 in Orlando, Orange County, Florida.
`
`12. At that time and place, Defendant, MICHAEL LARSON, was operating a motor vehicle
`traveling owned by Defendant, SPECIALTY DISTRIBUTION GROUP, LLCDefendant,
`MICHAEL LARSON, was operating and driving the motor vehicle with the permission and
`consent of its owner, Defendant, SPECIALTY DISTRIBUTION GROUP, LLC.
`
`13. At that time and place, Defendant, MICHAEL LARSON negligently operated and/or
`maintained the motor vehicle so that it caused an impact with Plaintiff's motor vehicle.
`
`14. As a direct and proximate result of Defendants’ negligence, Plaintiff 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.
`
`15. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future.
`Plaintiff's motor vehicle was also damaged.
`
`WHEREFORE, Plaintiff, SARA THOMAS-GONCALVES, demands judgment for
`damages against Defendants MICHAEL LARSON, and other such relief deemed proper by the
`Court.
`
`COUNT IT - CLAIM OF NEGLIGENCE AGAINST DEFENDANT, SPECIALTY
`DISTRIBUTION GROUP, LLC
`
`16. Plaintiff, adopts, realleges those allegations contained within paragraphs 1-16, above and
`
`incorporates them herein by reference, and further states:
`
`
`
`
`
`
`
`
`17.
`
`18.
`
`19.
`
`20.
`
`21.
`
`22.
`
`On or about April 21, 2025, Plaintiff was a passenger in a motor vehicle traveling at or near
`Interstate 4 and State Road 535 in Orlando, Orange County, Florida.
`
`At that time and place, Defendant, MICHAEL LARSON, was operating a motor vehicle
`traveling owned by Defendant, SPECIALTY DISTRIBUTION GROUP, LLCDefendant,
`MICHAEL LARSON, was operating and driving the motor vehicle with the permission and
`consent of its owner, Defendant, SPECIALTY DISTRIBUTION GROUP, LLC.
`
`At that time and place, Defendant, MICHAEL LARSON negligently operated and/or
`maintained the motor vehicle so that it caused an impact with Plaintiff's motor vehicle.
`Defendant, SPECIALTY DISTRIBUTION GROUP, LLC, is vicariously liable for the
`negligence of Defendant, MICHAEL LARSON, pursuant to the Florida Dangerous
`Instrumentality Doctrine because Defendant, SPECIALTY DISTRIBUTION GROUP, LLC,
`owned the vehicle operated by Defendant, MICHAEL LARSON, at the time of the subject
`car collision.
`
`Defendant, SPECIALTY DISTRIBUTION GROUP, LLC, is vicariously liable for the
`negligence of Defendant, MICHAEL LARSON, pursuant to the doctrine of Respondeat
`Superior, because Defendant, MICHAEL LARSON, was in the course and scope of his
`employment with Defendant, SPECIALTY DISTRIBUTION GROUP, LLC, at the time of
`the subject car collision.
`
`As a direct and proximate result of Defendants’ negligence, Plaintiff 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.
`23. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future.
`Plaintiff's motor vehicle was also damaged.
`WHEREFORE, Plaintiff; SARA THOMAS-GONCALVES, demands judgment for
`damages against Defendants SPECIALTY DISTRIBUTION GROUP, LLC, and other such relief
`deemed proper by the Court.
`
`DEMAND FOR JURY TRIAL
`
`Plaintiff also demands a jury trial on all issues so triable.
`
`RESPECTFULLY submitted this 4th day of September, 2025.
`
`Stephen Lynch,
`
`FBN: 1024807
`
`Morgan & Morgan, P.A.
`
`20 N. Orange Avenue
`
`Suite 1600
`
`Orlando, FL 32801
`
`Telephone: (689) 219-2085
`
`Facsimile: (689) 219-2185
`
`Primary email: slynch@forthepeople.com
`Secondary email: cmolina@forthepeople.com
`Attorney for Plaintiff
`
`
`
`
`
`
`
`
`
`
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