Our Florida nursing home abuse attorneys recently filed the below wrongful death lawsuit against Palm Garden of Vero.
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Read the Lawsuit Filed Against Palm Garden of Vero
IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT, IN AND FOR INDIAN RIVER COUNTY, FLORIDA
CASE NO.:
PLAINTIFF as Personal Representative of the Estate of PLAINTIFF,
Plaintiff,
vs.
PALM GARDEN OF VERO BEACH, LLC d/b/a PALM GARDEN OF VERO BEACH; PALM HEALTHCARE MANAGEMENT, LLC; and PALM GARDEN HEALTHCARE HOLDINGS, LLC.
Defendants.
____________________________________/
COMPLAINT
COMES NOW the Plaintiff, PLAINTIFF as Personal Representative of the Estate of PLAINTIFF, by and through undersigned counsel, and sues the Defendants, PALM GARDEN OF VERO BEACH, LLC d/b/a PALM GARDEN OF VERO BEACH (hereafter “PALM GARDEN NURSING HOME”), PALM HEALTHCARE MANAGEMENT, LLC (hereafter “PALM GARDEN MANAGEMENT”) and PALM GARDEN HEALTHCARE HOLDINGS, LLC (hereafter “PALM GARDEN CORPORATE”) and further alleges:
GENERAL JURISDICTIONAL ALLEGATIONS
1. This is a cause of action for damages, which exceeds Fifteen Thousand Dollars ($15,000.00), exclusive of costs, interest, and attorney’s fees, is being filed within the applicable statute of limitations.
2. All conditions precedent to the filing of this action, including compliance with the notice provisions of Chapter 400, have been met or waived.
3. This action is being brought by the Plaintiff for violations of Chapter 400 and wrongful death against PALM GARDEN NURSING HOME, PALM GARDEN MANAGEMENT and PALM GARDEN CORPORATE while PLAINTIFF was a resident at the Defendants’ nursing home (hereafter “the nursing home” or “the facility”).
4. At all times material, PLAINTIFF has been appointed as Personal Representative of the Estate of PLAINTIFF, and is the proper party to bring this action on behalf of the estate and its survivors. See Exhibit “A”; Letters of Administration for the Estate of PLAINTIFF.
5. At all times material, PALM GARDEN NURSING HOME, was a Florida for-profit corporation doing business in Indian River County.
6. PALM GARDEN NURSING HOME committed tortious acts against PLAINTIFF in the State of Florida. Each tortious act is specifically alleged in the subsequent counts. Accordingly, PALM GARDEN NURSING HOME is subject to the jurisdiction of the court of the State of Florida.
7. At all times material, PALM GARDEN MANAGEMENT, was a Florida for-profit corporation doing business in Indian River County.
8. PALM GARDEN MANAGEMENT committed tortious acts against PLAINTIFF in the State of Florida. Each tortious act is specifically alleged in the subsequent counts. Accordingly, PALM GARDEN MANAGEMENT is subject to the jurisdiction of the court of the State of Florida.
9. At all times material, PALM GARDEN CORPORATE, was a Florida for-profit corporation doing business in Indian River County.
10. PALM GARDEN CORPORATE committed tortious acts against PLAINTIFF in the State of Florida. Each tortious act is specifically alleged in the subsequent counts. Accordingly, PALM GARDEN CORPORATE is subject to the jurisdiction of the court of the State of Florida.
11. At all times material hereto, the Defendants were subject to the provisions of Chapter 400 of Florida Statutes, Title 42 of the Code of Federal Regulations, Titles 10 and 59 of the Florida Administrative Code, and OBRA 1987, which set the standards for operating nursing homes such as this facility.
12. Venue is appropriate in this action as the events giving rise to the cause of action occurred in Indian River County, Florida, the subject facility is located in Indian River County, Florida, and one or more of the Defendants operate and do business in Indian River County, Florida.
13. The undersigned certifies a good faith basis for bringing this action.
ALLEGATIONS AGAINST PALM GARDEN NURSING HOME
14. At all times material hereto, the Defendant, PALM GARDEN NURSING HOME, was the licensee of the nursing home facility, which was authorized to do business in the State of Florida and principal place of business in Indian River County and to operate a nursing home under the name of Palm Garden of Vero Beach and is subject to the provisions of Florida Statutes Chapter 400.
15. At all times material hereto, the Defendant, PALM GARDEN NURSING HOME employed the nurses and caretakers at the facility, and is therefore responsible for their tortious conduct.
16. At all times material hereto, the Defendant, PALM GARDEN NURSING HOME, was operating the facility and/or had a non-delegable duty to ensure reasonable operation of the facility and reasonable care to residents, as the licensee of the facility, licensed as a nursing home as that term is defined in Florida Statutes Chapter 400.
17. At all times material hereto, PALM GARDEN NURSING HOME owed a duty to its residents, including PLAINTIFF, to exercise reasonable care in its operation of the subject nursing home according to §400.023(3), Florida Statutes.
ALLEGATIONS AGAINST PALM GARDEN MANAGEMENT
18. At all times material, the Defendant, PALM GARDEN MANAGEMENT, was the management/consulting company, manager and/or owner of the subject nursing home.
19. At all times material hereto, the Defendant, PALM GARDEN MANAGEMENT, was in the business of owning, managing, and/or maintaining nursing and convalescent homes and related health care facilities, including the subject facility in Indian River County.
20. At all times material hereto, the Defendant, PALM GARDEN MANAGEMENT, was operating the Defendants’ facility and/or had a non-delegable duty to ensure reasonable operation of the facility and reasonable care to residents, as the management company for the facility, which was licensed as a nursing home as that term is defined in Florida Statutes Chapter 400.
21. At all times material hereto, the Defendant, PALM GARDEN MANAGEMENT owned, operated, managed and controlled the nursing home’s operations, including but not limited to hiring/firing the facility’s administrator and/or director of nursing, employee training, staffing levels, budget and the facility’s policies and procedures in accordance with §400.023(2)(b), Florida Statutes.
22. During PLAINTIFF’s residency, the Defendant, PALM GARDEN MANAGEMENT owned, operated, managed and controlled the nursing home and its staff. Therefore, PALM GARDEN MANAGEMENT is responsible for any actions or omissions of the nursing home’s employees, agents or apparent agents.
23. PALM GARDEN MANAGEMENT owned, operated, managed, controlled and oversaw PALM GARDEN NURSING HOME and as such, owed a duty to PLAINTIFF to exercise reasonable care according to §400.023(3), Florida Statutes.
ALLEGATIONS AGAINST PALM GARDEN CORPORATE
24. At all times material, the Defendant, PALM GARDEN CORPORATE, was the manager and/or owner of the subject nursing home.
25. At all times material hereto, the Defendant, PALM GARDEN CORPORATE, was in the business of owning, managing, and/or maintaining nursing and convalescent homes and related health care facilities, including the subject facility in Indian River County.
26. At all times material hereto, the Defendant, PALM GARDEN CORPORATE, was operating the Defendants’ facility and/or had a non-delegable duty to ensure reasonable operation of the facility and reasonable care to residents, as the management company for the facility, which was licensed as a nursing home as that term is defined in Florida Statutes Chapter 400.
27. At all times material hereto, the Defendant, PALM GARDEN CORPORATE, owned, operated, managed and controlled the nursing home’s operations, including but not limited to hiring/firing the facility’s administrator and/or director of nursing, employee training, staffing levels, budget and the facility’s policies and procedures in accordance with §400.023(2)(b), Florida Statutes.
28. During PLAINTIFF’s residency, the Defendant, PALM GARDEN CORPORATE owned, operated, managed and controlled the nursing home and its staff. Therefore, PALM GARDEN MANAGEMENT is responsible for any actions or omissions of the nursing home’s employees, agents or apparent agents.
29. PALM GARDEN CORPORATE owned, operated, managed, controlled and oversaw PALM GARDEN NURSING HOME and as such, owed a duty to PLAINTIFF to exercise reasonable care according to §400.023(3), Florida Statutes.
FACTS GIVING RISE TO THIS NURSING HOME NEGLIGENCE LAWSUIT
30. PLAINTIFF was admitted to PALM GARDEN NURSING HOME for supervision and assistance with all activities of daily living.
31. PLAINTIFF was at all times a high fall risk and required appropriate fall precautions, including extensive assistance with supervision, ambulation, toileting, medication management and transfers.
32. Despite her high fall risk classification, proper fall preventative measures were not implemented at PALM GARDEN NURSING HOME.
33. During her residency at PALM GARDEN NURSING HOME, PLAINTIFF was neglected. She suffered multiple preventable falls and corresponding hospitalizations.
34. After each fall, proper fall preventative measures were not put in place.
35. Consequently, PLAINTIFF continued to suffer falls at PALM GARDEN NURSING HOME.
36. Of significance, on or about March 21, 2018, PLAINTIFF suffered a preventable fall and serious injuries. She was transferred and admitted to Indian River Medical Center for her facility-acquired injuries.
37. At the hospital, PLAINTIFF was diagnosed with a severe left hip fracture status post-fall, she was septic and dehydrated and had a urinary tract infection (UTI).
38. Due to her facility acquired injuries, PLAINTIFF’s underlying health conditions, both physical and mental, were greatly compromised.
39. PLAINTIFF died shortly thereafter on or around March 30, 2018.
WRONGFUL DEATH DAMAGES
40. PLAINTIFF wrongfully died on March 30, 2018 as a direct and proximate result of the Defendants’ negligence, more fully described above and below. According to the death certificate, the Cause of Death and Injury Information is as follows:
MANNER OF DEATH: ACCIDENT
CAUSE OF DEATH: SEPSIS, URINARY TRACT INFECTION, ACCIDENTAL FALL WITH RESULTANT HIP FRACTURE CONTRIBUTING TO DEATH
PLACE OF INJURY: PALM GARDEN OF VERO BEACH
41. As a direct and proximate result of the rights violations outlined above and below, the Estate of PLAINTIFF and the survivors of the Estate, including but not limited to PLAINTIFF III (son), PLAINTIFF and are entitled to all damages recoverable for the wrongful death caused by the Defendants, as alleged above and below, including but not limited to:
a. Damages for PLAINTIFF’s bodily injury, pain and suffering, disability, disfigurement, mental anguish, loss of the capacity for the enjoyment of life, expensive hospitalization, the value of reasonable nursing services and nursing care provided to PLAINTIFF, medical and nursing care and treatment and aggravation of previous existing conditions, from the time of his/her injury until the time of his/her death;
b. Medical bills and expenses;
c. Funeral expenses;
d. Loss of Net Accumulations;
e. The survivors of the deceased have suffered mental pain and suffering which will continue for the rest of their life, and they have suffered the loss of services and support of their loved one, PLAINTIFF, and have incurred medical and funeral expenses as a result of PLAINTIFF’s death, and have suffered the loss of PLAINTIFF ’s love and companionship.
SURVIVAL DAMAGES
42. Alternatively, if these injuries did not cause PLAINTIFF’s death, the Estate of PLAINTIFF claims all damages recoverable under a survival action, including but not limited to the non-economic and economic damages of the decedent for 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, and aggravation of a previously existing condition, from time of injury of PLAINTIFF to the time of his/her death. These survival damages occurred as a direct and proximate result of the negligence of the Defendants’ outlined above and below.
COUNT I:
PLAINTIFF v. PALM GARDEN NURSING HOME – WRONGFUL DEATH
43. Plaintiff re-adopts and re-alleges paragraphs 1 through 41 and further alleges:
44. Defendant, PALM GARDEN NURSING HOME, through its employees, agents and apparent agents were below the standard of care and thus violated the Chapter 400 rights of PLAINTIFF as follows:
i. Failure to properly and safely assess falls;
ii. Failure to properly and safely prevent falls;
iii. Failure to use a bed alarm and chair alarm in a fall risk resident;
iv. Failure to timely react to the resident’s injuries;
v. Failure to properly evaluate fall risk;
vi. Failure to institute appropriate fall precautions and provide assistive devices;
vii. Failure to appropriately and timely respond to fall precautions;
viii. Failure to prevent the falls of the resident;
ix. Failure to document the resident’s injuries;
x. Failure to report the resident’s injuries;
xi. Failure to inform the resident’s family of the resident’s deteriorated condition;
xii. Failure to monitor the resident;
xiii. Failure to appropriate staff and train employees and agents;
xiv. Failure to prevent infection;
xv. Failure to prevent skin breakdown and infection;
xvi. Failure to provide appropriate nutrition and hydration;
xvii. Failure to provide medication when required;
xviii. Failure to provide appropriate budgeting for the subject facility;
xix. Failure to properly staff the subject facility;
xx. Failure to provide appropriate policies and procedures to the subject facility; and,
xxi. Failure to provide appropriate nursing home care under all the circumstances.
45. The above negligence occurred from the actions and omissions of employees, agents and apparent agents of Defendant, PALM GARDEN NURSING HOME, while in the course and scope of their employment, agency and/or apparent agency.
46. As a proximate result of the Defendant’s deprivation of and infringement upon PLAINTIFF’s Chapter 400 rights as alleged in this Complaint, which includes the above alleged negligence, PLAINTIFF wrongfully died.
WHEREFORE, the Plaintiff, Estate of PLAINTIFF, demands judgment for damages against Defendant, PALM GARDEN NURSING HOME, and further demand a trial by jury of all issues so triable.
COUNT II:
PLAINTIFF v. PALM GARDEN MANAGEMENT – WRONGFUL DEATH
47. Plaintiff re-adopts and re-alleges paragraphs 1 through 41 and further alleges:
48. Defendant, PALM GARDEN MANAGEMENT, through its employees, agents and apparent agents were below the standard of care and thus violated the Chapter 400 rights of PLAINTIFF as follows:
i. Failure to properly and safely assess falls;
ii. Failure to properly and safely prevent falls;
iii. Failure to use a bed alarm and chair alarm in a fall risk resident;
iv. Failure to timely react to the resident’s injuries;
v. Failure to properly evaluate fall risk;
vi. Failure to institute appropriate fall precautions and provide assistive devices;
vii. Failure to appropriately and timely respond to fall precautions;
viii. Failure to prevent the falls of the resident;
ix. Failure to document the resident’s injuries;
x. Failure to report the resident’s injuries;
xi. Failure to inform the resident’s family of the resident’s deteriorated condition;
xii. Failure to monitor the resident;
xiii. Failure to appropriate staff and train employees and agents;
xiv. Failure to prevent infection;
xv. Failure to prevent skin breakdown and infection;
xvi. Failure to provide appropriate nutrition and hydration;
xvii. Failure to provide medication when required;
xviii. Failure to provide appropriate budgeting for the subject facility;
xix. Failure to properly staff the subject facility;
xx. Failure to provide appropriate policies and procedures to the subject facility; and,
xxi. Failure to provide appropriate nursing home care under all the circumstances.
49. The above negligence occurred from the actions and omissions of employees, agents and apparent agents of Defendant, PALM GARDEN MANAGEMENT, while in the course and scope of their employment, agency and/or apparent agency.
50. As a proximate result of the Defendant’s deprivation of and infringement upon PLAINTIFF’s Chapter 400 rights as alleged in this Complaint, which includes the above alleged negligence, PLAINTIFF wrongfully died.
WHEREFORE, the Plaintiff, Estate of PLAINTIFF, demands judgment for damages against Defendant, PALM GARDEN MANAGEMENT, and further demand a trial by jury of all issues so triable.
COUNT III:
PLAINTIFF v. PALM GARDEN CORPORATE – WRONGFUL DEATH
51. Plaintiff re-adopts and re-alleges paragraphs 1 through 41 and further alleges:
52. Defendant, PALM GARDEN CORPORATE through its employees, agents and apparent agents were below the standard of care and thus violated the Chapter 400 rights of PLAINTIFF as follows:
i. Failure to properly and safely assess falls;
ii. Failure to properly and safely prevent falls;
iii. Failure to use a bed alarm and chair alarm in a fall risk resident;
iv. Failure to timely react to the resident’s injuries;
v. Failure to properly evaluate fall risk;
vi. Failure to institute appropriate fall precautions and provide assistive devices;
vii. Failure to appropriately and timely respond to fall precautions;
viii. Failure to prevent the falls of the resident;
ix. Failure to document the resident’s injuries;
x. Failure to report the resident’s injuries;
xi. Failure to inform the resident’s family of the resident’s deteriorated condition;
xii. Failure to monitor the resident;
xiii. Failure to appropriate staff and train employees and agents;
xiv. Failure to prevent infection;
xv. Failure to prevent skin breakdown and infection;
xvi. Failure to provide appropriate nutrition and hydration;
xvii. Failure to provide medication when required;
xviii. Failure to provide appropriate budgeting for the subject facility;
xix. Failure to properly staff the subject facility;
xx. Failure to provide appropriate policies and procedures to the subject facility; and,
xxi. Failure to provide appropriate nursing home care under all the circumstances.
53. The above negligence occurred from the actions and omissions of employees, agents and apparent agents of Defendant, PALM GARDEN CORPORATE, while in the course and scope of their employment, agency and/or apparent agency.
54. As a proximate result of the Defendant’s deprivation of and infringement upon PLAINTIFF’s Chapter 400 rights as alleged in this Complaint, which includes the above alleged negligence, PLAINTIFF wrongfully died.
WHEREFORE, the Plaintiff, Estate of PLAINTIFF, demands judgment for damages against Defendant, PALM GARDEN CORPORATE, and further demand a trial by jury of all issues so triable.
COUNT IV:
PLAINTIFF v. PALM GARDEN NURSING HOME – SURVIVAL ACTION
55. Plaintiff re-adopts and re-alleges paragraphs 1 through 39 and 42 and further alleges:
56. Defendant, PALM GARDEN NURSING HOME, through its employees, agents and apparent agents were below the standard of care and thus violated the Chapter 400 rights of PLAINTIFF as follows:
i. Failure to properly and safely assess falls;
ii. Failure to properly and safely prevent falls;
iii. Failure to use a bed alarm and chair alarm in a fall risk resident;
iv. Failure to timely react to the resident’s injuries;
v. Failure to properly evaluate fall risk;
vi. Failure to institute appropriate fall precautions and provide assistive devices;
vii. Failure to appropriately and timely respond to fall precautions;
viii. Failure to prevent the falls of the resident;
ix. Failure to document the resident’s injuries;
x. Failure to report the resident’s injuries;
xi. Failure to inform the resident’s family of the resident’s deteriorated condition;
xii. Failure to monitor the resident;
xiii. Failure to appropriate staff and train employees and agents;
xiv. Failure to prevent infection;
xv. Failure to prevent skin breakdown and infection;
xvi. Failure to provide appropriate nutrition and hydration;
xvii. Failure to provide medication when required;
xviii. Failure to provide appropriate budgeting for the subject facility;
xix. Failure to properly staff the subject facility;
xx. Failure to provide appropriate policies and procedures to the subject facility; and,
xxi. Failure to provide appropriate nursing home care under all the circumstances.
57. The above negligence occurred from the actions and omissions of employees, agents and apparent agents of Defendant, PALM GARDEN NURSING HOME, while in the course and scope of their employment, agency and/or apparent agency.
58. This Count is being pleaded in the alternative to the above wrongful death Count. If these injuries did not cause the death of PLAINTIFF , the Plaintiff alleges all damages recoverable under a survival action, including but not limited to the non-economic damages of decedent for 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, and aggravation of a previously existing condition, from time of injury of PLAINTIFF to the time of his/her death.
WHEREFORE, the Plaintiff, Estate of PLAINTIFF, demands judgment for damages against Defendant, PALM GARDEN NURSING HOME, and further demand a trial by jury of all issues so triable.
COUNT V:
PLAINTIFF v. PALM GARDEN MANAGEMENT – SURVIVAL ACTION
59. Plaintiff re-adopts and re-alleges paragraphs 1 through 39 and 42 and further alleges:
60. Defendant, PALM GARDEN MANAGEMENT, through its employees, agents and apparent agents were below the standard of care and thus violated the Chapter 400 rights of PLAINTIFF as follows:
i. Failure to properly and safely assess falls;
ii. Failure to properly and safely prevent falls;
iii. Failure to use a bed alarm and chair alarm in a fall risk resident;
iv. Failure to timely react to the resident’s injuries;
v. Failure to properly evaluate fall risk;
vi. Failure to institute appropriate fall precautions and provide assistive devices;
vii. Failure to appropriately and timely respond to fall precautions;
viii. Failure to prevent the falls of the resident;
ix. Failure to document the resident’s injuries;
x. Failure to report the resident’s injuries;
xi. Failure to inform the resident’s family of the resident’s deteriorated condition;
xii. Failure to monitor the resident;
xiii. Failure to appropriate staff and train employees and agents;
xiv. Failure to prevent infection;
xv. Failure to prevent skin breakdown and infection;
xvi. Failure to provide appropriate nutrition and hydration;
xvii. Failure to provide medication when required;
xviii. Failure to provide appropriate budgeting for the subject facility;
xix. Failure to properly staff the subject facility;
xx. Failure to provide appropriate policies and procedures to the subject facility; and,
xxi. Failure to provide appropriate nursing home care under all the circumstances.
61. The above negligence occurred from the actions and omissions of employees, agents and apparent agents of Defendant, PALM GARDEN MANAGEMENT, while in the course and scope of their employment, agency and/or apparent agency.
62. This Count is being pleaded in the alternative to the above wrongful death Count. If these injuries did not cause the death of PLAINTIFF , the Plaintiff alleges all damages recoverable under a survival action, including but not limited to the non-economic damages of decedent for 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, and aggravation of a previously existing condition, from time of injury of PLAINTIFF to the time of his/her death.
WHEREFORE, the Plaintiff, the Estate of PLAINTIFF, demands judgment for damages against Defendant, PALM GARDEN MANAGEMENT, and further demand a trial by jury of all issues so triable.
COUNT VI:
PLAINTIFF v. PALM GARDEN CORPORATE – SURVIVAL ACTION
63. Plaintiff re-adopts and re-alleges paragraphs 1 through 39 and 42 and further alleges:
64. Defendant, PALM GARDEN CORPORATE, through its employees, agents and apparent agents were below the standard of care and thus violated the Chapter 400 rights of PLAINTIFF as follows:
i. Failure to properly and safely assess falls;
ii. Failure to properly and safely prevent falls;
iii. Failure to use a bed alarm and chair alarm in a fall risk resident;
iv. Failure to timely react to the resident’s injuries;
v. Failure to properly evaluate fall risk;
vi. Failure to institute appropriate fall precautions and provide assistive devices;
vii. Failure to appropriately and timely respond to fall precautions;
viii. Failure to prevent the falls of the resident;
ix. Failure to document the resident’s injuries;
x. Failure to report the resident’s injuries;
xi. Failure to inform the resident’s family of the resident’s deteriorated condition;
xii. Failure to monitor the resident;
xiii. Failure to appropriate staff and train employees and agents;
xiv. Failure to prevent infection;
xv. Failure to prevent skin breakdown and infection;
xvi. Failure to provide appropriate nutrition and hydration;
xvii. Failure to provide medication when required;
xviii. Failure to provide appropriate budgeting for the subject facility;
xix. Failure to properly staff the subject facility;
xx. Failure to provide appropriate policies and procedures to the subject facility; and,
xxi. Failure to provide appropriate nursing home care under all the circumstances.
65. The above negligence occurred from the actions and omissions of employees, agents and apparent agents of Defendant, PALM GARDEN CORPORATE, while in the course and scope of their employment, agency and/or apparent agency.
66. This Count is being pleaded in the alternative to the above wrongful death Count. If these injuries did not cause the death of PLAINTIFF , the Plaintiff alleges all damages recoverable under a survival action, including but not limited to the non-economic damages of decedent for 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, and aggravation of a previously existing condition, from time of injury of PLAINTIFF to the time of his/her death.
WHEREFORE, the Plaintiff, the Estate of PLAINTIFF, demands judgment for damages against Defendant, PALM GARDEN CORPORATE, and further demand a trial by jury of all issues so triable.
DATED this 29th day of March, 2019.
/s/ William J. Sarubbi, II, Esq._______
WILLIAM J. SARUBBI, II, ESQ.
Florida Bar No.: 113401
Senior Justice Law Firm
1903 S. Congress Ave., Suite 380
Boynton Beach, Florida 33426
Phone: (561) 717-0813
Fax: (561) 708-6781
Email: eservice@SeniorJustice.com
Attorney for Plaintiff(s)
