Defendant's Attorney: Jacksonville, Florida insurance defense lawyers represented the Defendants.

Description: Jacksonville, Florida personal injury lawyers represented the Plaintiff who sued the Defendant on a product liability theory.


COMPLAINT

Plaintiff, ROBERT HETSLER, by and through the undersigned counsel, brings this Complaint against Defendants, FORD MOTOR COMPANY (‘FORD”), ROUSH PERFORMANCE (‘ROUSH”), and WORLD IMPORTS, USA, INC. ("WIU").

At all relevant times, Defendant, FORD, was and is a foreign profit corporation authorized to and doing business throughout the State of Florida, for which it receives substantial revenue. FORD is engaged in the business of designing, manufacturing, marketing, promoting, advertising, and selling motor vehicles in the State of Florida and
throughout the United States and elsewhere. FORD’ principal place of business is in Dearborn, Wayne County, Michigan.

4. Defendant, FORD, submitted itself to the jurisdiction of this Honorable Court by doing personally, or through its agents, at all times material to this action, the following acts: (a) Conducting and engaging in substantial business and other activities in Florida by servicing defective automobiles, including the Subject 2016 Ford Roush Mustang in this matter, to persons, finns, or corporations in this state via its distributors, dealers, wholesalers and brokers. Such automobiles, including the Subject 2016 Ford Roush Mustang, were used by consumers in Florida in the ordinary course of commerce and trade; (b) Committing a tortious act within this state by designing, ‘manufacturing and distributing defective automobiles, including the Subject 2016 Ford Roush Mustang, to persons, firms, or corporations in Florida via its distributors, dealers, wholesalers, and brokers. Such automobiles, including the Subject 2016 Ford Roush Mustang, were used by consumers in Florida in the ordinary course of commerce and trade; (6) Causing injury to persons in Florida, including ROBERT HETSLER. At or about the time said injuries occurred, Defendant, FORD, engaged in solicitation activities in Florida to promote the sale, consumption, use, maintenance, and repair of its automobiles; products designed, serviced and manufactured by FORD were consumed within Florida in the ordinary course of commerce; and FORD was engaged in substantial and not isolated activity within this state; and (4) Selling and delivering defective automobiles, including the Subject 2016 Ford Roush Mustang, to persons, firms, or corporations via its distributors, dealers, wholesalers, and brokers, with knowledge or reason to foresee that its automobiles, in interstate commerce, would reach the market of Florida users or consumers.

The vehicle that is the subject of this Complaint is a 2016 Ford Roush Mustang (VIN #IFAGPSCFIGS247461), hereinafter “Subject Vehicle.”

The events, act, errors, and/or omissions, which are subject matter of this Complaint, occurred in Duval County, Florida.

On or about November6,2017, ROBERT HETSLER purchased the subject vehicle. from Defendant, WIU.

At the time of purchase the Subject Vehicle had less than 1,000 miles on its odometer and was previously owned by only one other person.

At the time of purchase, WIU informed and represented to ROBERT HETSLER that the Subject Vehicle was freeof defects and safe for use. WIU provided no warnings regarding the fire danger posed by the Subject Vehicle

On or about November 16, 2017, ten days after he purchased the Subject Vehicle, ROBERT HETSLER was seated in the Subject Vehicle in a parking lot behind the Southbank Pharmacy in Jacksonville, Florida.

Based on information and belief, at the same time and place, due to defects or improperly installed components in the Subject Vehicle, a fire began out side of the engine compartment of the vehicle before it rapidly and unexpectedly engulfed the Subject Vehicle (‘Subject Fire”), including the interior passenger compartment.

At the time of emergency response ROBERT HETSLER was found approximately 100 feet away from the burning Subject Vehicle disoriented, with his clothes and body badly burned

As a result of the Subject Fire, ROBERT HETSLER, was transported via ambulance to UF Health Shands "Burn Center where he was treated for catastrophic third and fourth degree burns over approximately 74% of his body - from his hair line to his belly button - leaving the front of his face to his collar bone the only parts of his upper body unscathed by bums.

Outcome: Plaintiff's verdict for $104.6 million.

Plaintiff's Experts:

Defendant's Experts:

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