Case 1:20-cv-00127-AW-GRJ Document 94 Filed 04/16/21 Page 2 of 2

4, Did Plaintiff, MARCELLE ANN ANGALL-LEONCE, sustain a permanent injury
within a reasonable degree of medical probability as a result of the incident complained of?

ANSWER: YES. NO_X
If your answer to question 4 is NO, you should not proceed further except to date and sign this

verdict form and return it to the courtroom. If your answer to question 4 is YES, please answer
question 5.

5. What is the total amount of damages of Plaintiff, MARCELLE ANN ANGALL-
LEONCE, for pain and suffering, bodily injury, disability, aggravation of prior medical condition,
mental anguish, and loss of capacity for the enjoyment of life, sustained in the past and to be
sustained in the future?

a. in the past? $.

b. in the future? $

c. Total of the above damages (add lines 5a and Sb): $s
Total of the above damages (add lines 3c and Sc): —————
Please answer question 6,

6. What is the total amount of any damages of Plaintiff, ROMANUS SYLVESTER
LEONCE, for loss, by reason of his wife's injury, of her services, comfort, society, and attentions,

a. in the past? $_S5S,000
b. in the future? §
¢. Total of the above damages (add lines 6a and 6b): $_ 5,000

SO SAY WE ALL, this Ifo day of April, 2021.


Case 1:20-cv-00127-AW-GRJ Document 94 Filed 04/16/21 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF FLORIDA
GAINESVILLE DIVISION

MARCELLE ANN ANGALL-LEONCE
and ROMANUS SYLVESTER LEONCE,

Plaintiffs,
v. Case No.: 1:20-cv-127-AW-GRJ

ON POINT TRANSPORT, INC., and
JOSEPH MISATULI LEIA

Defendants.
fj

VERDICT

We, the jury, return the following verdict:

1 Was there negligence on the part of Defendant, JOSEPH MISATULI LEIA, which
was a legal cause of damage to the Plaintiff, MARCELLE ANN ANGALL-LEONCE?

ANSWER: YES__X NO.

If your answer to question I is NO, your verdict is for the Defendants, and you should not proceed
further, except to date and sign this verdict form and return it to the courtroom. If your answer to
question | is YES, please answer question 2.

2, What is the amount of any damages sustained by Plaintiff, MARCELLE ANN
ANGALL-LEONCE, for medical expenses,

a. in the past? $10,000
b. in the future? $100,000

Please answer question 3.

3. What is the amount of any damages sustained by the Plaintiff, MARCELLE ANN
ANGALL-LEONCE, for lost earnings or earning ability,

a, in the past? $_380,c00
b. in the future? $__ 200,000
c. Total of the above damages (add lines 2a, 2b, 3a and 3b) s 180,000
Please answer question 4, Filedin Op n Court
~[(p-30 af

Clerk/U.S. District Curt
Northern District -f Flonda


IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF FLORIDA
GAINESVILLE DIVISION

MARCELLE ANN ANGALL-LEONCE
and ROMANUS SYLVESTER LEONCE, CASE NO.: 1:20-cv-127-AW-GRJ

Plaintiffs,
vs.

ON POINT TRANSPORT, INC. and
JOSEPH MISATULI LEIA,

Defendants.
/

PLAINTIFFS’ MOTION FOR FINAL JUDGMENT

COME NOW the Plaintiffs, MARCELLE ANN ANGALL-LEONCE and
ROMANUS SYLVESTER LEONCE, by and through their undersigned Counsel,
and hereby move this Honorable Court, pursuant to Federal Rule of Civil Procedure
58 for the entry of a Final Judgment against Defendants with reservation of jurisdiction
for the court to award costs and for other post judgment issues and in support thereof

the following would be shown:

1. Plaintiffs, MARCELLE ANN ANGALL-LEONCE and ROMANUS
SYLVESTER LEONCE, instituted this action against Defendants, ON POINT
TRANSPORT, INC. and JOSEPH MISATULI LEIA, on July 26, 2019.

2. This case was tried to a jury verdict on April 12, 2021 through April 16,

2021.

+ FINE, FARKASH & PARLAPIANO, P.A.*
622 NE First Street, Gainesville, FL 32601 * TEL #(352) 372-7777 » FAX #(877) 272-9101
Page 1 of 3


3. On April 16, 2021, after a jury trial, a verdict was returned in favor of the
Plaintiffs in the amount of $755,000. A copy of the verdict form awarding $755,000

to the Plaintiffs is attached as Exhibit 1.

4. Federal Rule of Civil Procedure 58(b) allows judgment to be entered either

by the Clerk or upon Court approval.
5. Federal Rule of Civil Procedure 54 allows for costs following the Judgment.

WHEREFORE, Plaintiffs respectfully request that this Court enter a judgment
pursuant to the verdict with reservation for costs.

MEMORANDUM OF LAW

Federal Rule of Civil Procedure 58 (b) provides for the entry of judgment after
the jury returns a general verdict. Given that the jury verdict was returned on April 16,
2021, it would be appropriate for the court to enter its judgment and considering that
Federal Rule of Civil Procedure 54(d)(1) allows for recovery of costs to the prevailing
party, Plaintiff would ask that the Judgment specifically reserve the Court's Jurisdiction
to award costs and for any other post-judgment issues which may be submitted
including, but not limited to, Defendants’ Renewed Motion for Directed Verdict,
Motion for Remittitur or Set-Off, or Motion for Award of Costs.

CONCLUSION
WHEREFORE the Plaintiffs respectfully request that this Honorable Court

enter a Final Judgment against the Defendants.

+ FINE, FARKASH & PARLAPIANO, P.A.«
622 NE First Street, Gainesville, FL 32601 = TEL #(352) 372-7777 « FAX #(877) 272-9101
Page 2 of 3


LOCAL RULE 7.1

CERTIFICATION
Plaintiffs hereby certify that pursuant to Local Rule 7.1(B) and prior to the
filing this Motion, the Undersigned conferred in good faith with opposing counsel
and that a resolution of this Motion was reached. The defense agrees to the entry of

Final Judgment as specified herein.

LOCAL RULE 7.1
WORD COUNT

Undersigned counsel hereby certifies that the word count in this Motion
and Memorandum of Law is 529 words in compliance with Local Rule 7.1(F).

CERTIFICATE OF SERVICE

I hereby certify that I electronically filed the foregoing with the Clerk of the
Court using the CM/ECF and to: John Moffitt Howell, Esq., E.T. Fernandez, Esq.,
Fernandez Trial Lawyers, PA (Attorneys for Defendants), 8780-200 Perimeter Park

Court, Jacksonville, FL 32216 pleadings(@fernandeztl.com.

jhowell@fernandeztl.com. on this 30! ay of April, 2021.

FINE, FARKASH & PARLAPIANO, P.A.
622 Northeast First Street

Gainesville, Florida 32601

Telephone: 3, ~6046; Fax: 877-272-9101

BY:
JACK FINE, ESQ
ttoyney for Plaintiff
orida Bar Number: 223700
Primary Email: jfine@ffplaw.com

» FINE, FARKASH & PARLAPIANO, P.A.*
622 NE First Street, Gainesville, FL 32601 * TEL #(352) 372-7777 « FAX #(877) 272-9101
Page 3 of 3