19-year-old Adrian De la Rosa suffered catastrophic injuries on March 11, 2023, as a result of this single-car accident. Liability was clear and there was no plausible liability defense. Christopher Baier was the permissive driver of a Tesla owned by the Roche family on the night of the accident. He was driving at a ridiculous rate of speed and lost control when he failed to navigate the traffic circle located on Ave Maria Boulevard in Collier County, Florida. As a result of the crash, Adrian De la Rosa was rendered a paraplegic.
Adrian suffered an L2 fracture with severe cauda equina compression. Adrian immediately lost sensation to his lower extremities. Adrian underwent a T12 to L4 instrumented fusion and laminectomy at L1-3. After his initial hospitalization, Adrian was transferred to the rehabilitation unit and was finally discharged on April 20, 2023… more than a month after he was hospitalized.
Adrian in rehabilitation
Adrian has a long, complex, and costly future due to his injuries. He will require extensive medical care for the remainder of his life. Presently, Adrian continues his rehabilitation three times per week. With the help of his family, he will continue to fight in his attempt to live as independent a life as possible.
Adrian before his tragic injury
The Haggard Law Firm has successfully litigated some of the most complex and catastrophic car crash casesfor more than 30 years. Haggard Law trial attorneys understand how to develop and execute effective litigation strategies in these complicated and tragic cases.
On March 20, 2022 the victim, Justin Acevedo, went to the BCC Apartments in Miami-Dade County to pick up a friend. While sitting in his car, an assailant walked up and began shooting at Mr. Acevedo. The vehicle was struck several times and Mr. Acevedo was shot once in the head just a day before his 18th birthday.
As a result of the shooting, Mr. Acevedo suffered severe, catastrophic, and permanent injuries. He was taken to the hospital and although initially responsive, he deteriorated quickly. He underwent a decompressive hemicraniectomy to relieve pressure in his brain. He was intubated for over a week and spent 15 days in the hospital. He was later discharged to an inpatient rehabilitation facility where he spent another 17 days. He was subsequently discharged and continued extensive therapy and rehabilitation. He also underwent a cranioplasty to repair his skull.
The Haggard Law Firm brought claims against the owner of the apartment complex (SP BCC LP) and property manager (Cambridge Management) on Mr. Acevedo’s behalf for failing to have reasonable security measures in place to prevent and deter criminal activity.
The apartment complex had a history of criminal activity, which included prior shootings, armed robberies, assaults, as well as other types of criminal activity. Despite the history of crime and the risk that existed to residents and guests, the Defendants did not have any security in place to address the risk. The property had no access control, surveillance cameras, or manned security.
Although Mr. Acevedo’s health has improved significantly, he continues to struggle with his injuries and recovery since the shooting. He still has significant cognitive deficits, including speech limitations and he often gets distracted and confused. He also lost the ability to control his right arm and hand and can’t fully ambulate. He continues to have severe headaches and gets dizzy often. In light of the foregoing issues, he isn’t able to fully care for himself and requires the assistance of his family to help him.
The names of the parties in the case are confidential per the terms of the settlement.
In the Fall of 2020, during the midst of the pandemic, a young mother moved across the country with her 3-year-old son and their dog. Laid off due to pandemic cutbacks, this mother and son sought to move in with a friend and start a new life in Brevard County, Florida. During the first full day in their new State, the mother was unpacking the car as she carried their belongings up and down three flights of stairs to the apartment. She left her son and their dog inside with the adult friend and her child. After making several trips up and down the stairs, the friend appeared in the parking lot and told her that she was leaving to pick up her elder son from school.
Immediately rushing upstairs to the apartment, the mother could not find her son. After searching the apartment, calling the police, and running throughout the complex, a police helicopter ultimately discovered the 3-year-old boy’s body at the bottom of a retention pond behind the apartment building. He drowned.
The Haggard Law Firm’s Michael HaggardThe Haggard Law Firm’s Adam Finkel
The mother filed a lawsuit against the owners and managers of the complex for negligently failing to maintain the apartment complex in a reasonable manner. In the lawsuit, The Haggard Law Firm highlighted that the land around the retention pond was too steep, and in fact, that there was a several-inch drop where the water met the land. Finkel and Haggard argued the drop from solid ground caused the child to fall into the water and made it difficult – if not impossible – for him to get out.
The Haggard Law Firm also highlighted that the owners and managers negligently closed off one of the stairwells that led from the building to the pond, thereby slowing down the mother’s path to the back of the apartment building. In response, the complex’s owners and managers argued that they followed all applicable regulatory laws regarding the pond and building, and even referenced a post-incident report from the local water management district that stated the pond’s slope was maintained in compliance with all laws.
The Haggard Law Firm has successfully litigated the most difficult drowning and near-drowning cases across the country for decades. Drowning is preventable. The law firm strives to achieve justice for families while also advocating for changes in laws to help prevent tragedies, such as this case, from happening to other families. The Haggard Law Firm is a proud partner of The National Drowning Prevention Alliance. Managing Partner Michael Haggard has been a board member of NDPA for several years.
$3 Million Negligent Security Wrongful Death Case Settlement
The Haggard Law Firm’s Douglas McCarron and Michael Haggard have secured a $3 Million settlement in a wrongful death negligent security case. The names of the parties involved are confidential per the terms of the settlement.
The victim, John Doe, was murdered at the “ABC Apartments” within SIX weeks of another killing at the very same complex. That case was settled for $1.75 Million. These brutal killings, both involving young men, continue the troubling and tragic consistent violence at the property.
The Defendants purchased the complex in September 2015 and took minimal to no effort to make the property safe. The apartment complex was the site of unrelenting violence – shootings, armed robberies, home invasions, batteries, and assaults. Despite these constant acts of violence, the property owner and the property management company failed to take security seriously and as a result, two young men lost their lives.
On December 14th, 2018, John Doe was shot and killed during a carjacking/armed robbery. The victim and his brothers were sitting in their car listening to music when two men approached holding firearms and started to attack and rob them. As the boys attempted to retreat from the brutal attack, the gunmen fired into the car. John Doe was killed, and his brother was wounded.
For years, and at the time of the incident, the property had limited and ineffective security measures. The property had been robbed and neighbors describe that there always seemed to be people hanging out on the property that appeared to be dealing in narcotics.
For more than three decades The Haggard Law Firm has successfully litigated thousands of premises liability negligent security cases. LEARN MORE
$19.5 Million Settlement Involving Negligent Security Cases Against Same Defendant
The Haggard Law Firm’s Pedro Echarte and Michael Haggard have obtained a $19.5 Million global settlement involving two separate negligent security cases against common defendants. While the incidents were entirely unrelated, the same common defendants owned and operated the two multi-family residential properties in South Florida. Both incidents happened only months apart from each other. The names of the parties are confidential. Because both incidents were covered by the same insurance policies, Echarte and Haggard negotiated the settlement of both cases for the available policy limits of $19,000,000 in addition to an extra $500,000 directly from the defendant property management company. Both cases settled shortly after the respective lawsuits were filed.
Pedro EcharteMichael Haggard
John Doe 1’s Case
On March 20, 2022, Haggard Law’s client John Doe 1 went to a South Florida apartment complex to pick up a friend. While sitting in his car, an assailant walked up and began shooting. The vehicle was struck several times and John Doe 1 was shot once in the head.
The victim brought claims against the owner of the apartment complex and the property manager for failing to have reasonable security measures in place to prevent and deter criminal activity. The apartment complex had a history of criminal activity, which included prior shootings, armed robberies, assaults, as well as other types of criminal activity. Despite that history of crime and the risk that existed there to residents and guests, the Defendants did not have any security in place to address the risk – the property had no access control, surveillance cameras, or manned security.
As a result of the shooting, the victim suffered severe, catastrophic, and permanent injuries. The victim was 17 years old (a day shy of 18th birthday) when he was shot. He was taken to the hospital and although initially responsive, he deteriorated quickly. He underwent a decompressive hemicraniectomy to relieve pressure in his brain. He was intubated for over a week and spent 15 days in the hospital. John Doe 1 was later discharged to an inpatient rehabilitation facility where he spent another 17 days. He was subsequently discharged and continued extensive therapy and rehabilitation. He also underwent a cranioplasty to repair his skull.
Since then he has improved significantly, but Joe Doe 1 continues to struggle with his injuries and recovery since the shooting. He still has significant cognitive deficits, including speech limitations and he often gets distracted and confused. He also lost the ability to control his right arm and hand and can’t fully ambulate. He continues to have severe headaches and gets dizzy often. Considering the foregoing issues, he can’t fully care for himself and requires the assistance of his family to help him.
John Doe 2’s Case
John Doe 2 was shot at a separate apartment complex that was also in South Florida, but in a different county than John Doe I. The Haggard Law Firm client worked in home maintenance and was hired by a resident in the Defendant’s community. In the course of doing his job, he was attacked by several people who started shooting him. Although they were arrested and charged, no motive was ever established for the shooting. However, it became apparent that the assailants tracked John Doe 2 to the apartment complex where he was attacked using a GPS tracking device they had placed on his vehicle several days before. The victim brought claims against the owner of the apartment complex and the property manager for failing to have reasonable security measures in place to prevent and deter criminal activity. The apartment complex had a history of criminal activity, which included one prior shooting, fights, and burglaries.
Despite that history of crime and the risk that existed there to residents and guests, the Defendants did not have any security in place to address the risk – the property had broken access control gates, no surveillance cameras, and no manned security. As a result of the shooting, the victim suffered severe, catastrophic, and permanent injuries. He was unresponsive and taken by fire rescue to the hospital after he was shot several times.
He had severe injuries to his face, head and brain (among other injuries) and underwent an emergency craniectomy, and a large portion of his skull was removed. He was initially hospitalized for an extensive period of time and underwent numerous surgical procedures. He was eventually discharged home and moved in with a loved one, who became his 24/7 caregiver. He has suffered from numerous complications since his discharge, including numerous infections and seizures that have required subsequent hospitalizations. He also went to a cranioplasty to repair his missing skull.
John Doe 2 continues to suffer from his injuries, including cognitive deficits and seizures. He has undergone extensive medical care and hospitalizations since he was first discharged. Many of these subsequent issues have been due to recurring infections. He is unable to care for himself and now lives with his loved one. He is no longer able to work.
On October 16, 2021, 24-year-old Jamal Drummond was visiting the Holiday Inn Express along Metrocentre Boulevard attending a party, when he was shot and killed. Drummond was a father of two.
Drummond with one of his minor children
That evening, a trespasser arrived at the hotel and walked around the property looking for a woman.
He had a photo of the woman on his phone, asking guests if they saw her. This man remained on the property without any lawful purpose. He was never approached by staff. The trespasser spent time within the hotel making loud noises near the front desk. The hotel staff still ignored him.
As Jamal and other partygoers were outside, the trespasser approached them and asked if they saw the woman. While they had not seen her, they asked the man why he was walking through the parking lot, looking into car windows. The trespasser became irritated by the question. Soon after, he returned again, confronted Drummond and the others, and ultimately shot and killed Drummond.
After an extensive investigation by police, Claudio Valdiviezo Samayoa, 29, was arrested for the murder.
On behalf of Drummond’s Estate, Finkel and Haggard filed suit in Palm Beach County Circuit Court against the owner and operator of the hotel, Metrolodging, LLC d/b/a Holiday Inn Express West Palm Beach Metro Centre, alleging that their negligence caused Drummond’s death. Specifically, the owners and operators of this Holiday Inn Express failed to reasonably train their employees, failed to reasonably secure the property with security guards, like many other nearby hotels did, and negligently failed to recognize that Samayoa had no business on the property and should have been removed.
The Haggard Law Firm’s Adam Finkel
While the hotel owners argued that they did nothing wrong, and highlighted that no similar crimes previously occurred at this property, and other than the occasional vehicle break-ins there was no real crime, they ultimately offered the full insurance policy limits of One Million Dollars ($1,000,000.00) to settle the case.
Jamal Drummond is survived by his parents, Pauline and Glenford Drummond, and his two minor children.
The Haggard Law Firm has been at the forefront of successfully litigating negligent security cases for more than three decades. Contact Haggard Law Firm Attorneys
$12.5 Million Settlement in Catastrophic Injury Boating Negligence Case
The Haggard Law Firm’s Kimberly Wald and Michael Haggard have secured a $12.5 Million settlement in a boating negligence case involving a 29-year-old rendered a quadriplegic during an excursion to a sandbar off of Fort Lauderdale.
Due to the terms of the settlement, the name of the parties is confidential.
On May 1, 2021, John Doe (The Haggard Law Firm’s client) and his friends chartered a boat and hired an experienced boat captain to take them around Fort Lauderdale on an afternoon booze cruise. The captain allowed John and his friends to bring alcohol and coolers onto the boat. The group first went to a local beach where they drank alcohol and partied for a while. After that, John passed out on the boat and awoke at the second destination, the Fort Lauderdale sandbar. When he woke up, he noticed his friends were all in the water so he dove head first off the boat. Unfortunately for John, this sandbar was very shallow and John suffered a spinal cord injury which left him, a 29-year-old, a quadriplegic.
Prior to his injury John was a bar manager at a local restaurant and was living completely independently. was dating a woman he thought he would marry one day. The catastrophic injury he suffered led to a breakup between the two. As a result of the catastrophic injuries he sustained, John had to move in with his parents who now are his caretakers and attend to him around the clock.
Defendants in this case claimed that John was at fault for his own injuries because he dove head first into a sandbar which he knew was very shallow and that the captain had warned all of the passengers, including John, of this danger. Defendants deposed many of the passengers on the boat, some of whom testified that they remembered some safety briefings but did not remember the details of those briefings.
Attorney Kimberly WaldManaging Partner Michael Haggard
Haggard and Wald argued that the safety briefings, even if they existed, were so vague and ambiguous no one knew what to expect or even what locations they were going to. Moreover, they argued the captain had the ultimate responsibility to monitor the alcohol consumption of the guests and had a duty to end the charter if any guest became intoxicated.
$13 Million Verdict in Product Liability Wrongful Death Case
The Haggard Law Firm’s Pedro Echarte and Todd Michaels have obtained a $13 Million verdict in a Miami – Dade County Court in a wrongful death product liability case involving the carbon monoxide poisoning death of a father of two.
On July 12, 2019, Matthew Burns died after succumbing to carbon monoxide poisoning resulting from his use and operation of a piece of machinery known as a “Shot Blaster, ” which he rented from Defendant SUNBELT RENTALS.
The Burns Family
Echarte and Michaels argued that SUNBELT RENTALS was negligent because it knew that the Shot Blaster would be operated in an indoor / partially enclosed environment and knew customers and operators like Mr. Burns were at significant risk for carbon monoxide poisoning.
Haggard Law attorneys explained how pursuant to manufacturer instructions and warnings in the machine’s manual, SUNBELT should have warned and or instructed Mr. Burns to use a portable carbon monoxide monitor to safely operate the machine and to receive certain training.
Mr. Burns left behind his wife Melissa and twin children Max and Mia.
$1.25 Million Settlement in Wrongful Death Case Involving County Bus and Motorcycle
The Haggard Law Firm’s Douglas McCarron has obtained a $1.25 Million settlement in an automobile crash wrongful death involving a Miami-Dade County bus.
On May 13th, 2019, Jason Sanchez was riding his motorcycle to work at approximately 7:49 a.m. He was traveling north on SW 107th Avenue in Miami-Dade County, Florida. As Mr. Sanchez approached the intersection of SW 107th Avenue and SW 176th Street, a Miami-Dade County Bus ran a clearly marked stop sign and entered the intersection. The bus driver drove the bus directly into the path of Mr. Sanchez, violating Mr. Sanchez’s right-of-way. Sanchez couldn’t avoid the bus. He crashed his motorcycle and died. The police investigation of the tragic accident showed that the bus driver was completely at fault.
After the incident, the bus driver gave several different versions of what occurred that day. Each one was different from the other. The dashboard camera footage clearly shows that the bus driver did not feel it necessary to come to a complete stop at several stop signs.
After running through a red light while making a right turn at 14 m.p.h., the bus driver rolled through three consecutive stop signs before arriving at SW 107 Avenue and SW 176 Street intersection. He then rolled through that stop sign while making a left-hand turn. This final violation of Florida law is what caused the collision that killed Jason Sanchez. The bus driver’s complete disregard for the public took an incredible son from his loving parents.
Since the case was against Miami-Dade County, it was necessary to file a Claims Bill in the Florida Legislature. The Claims Bill was passed in June 2023.
