Cindy Black still resides with her ex-boyfriend Scott Summers at 542 Scotland Street, Apt. 12, Dunedin, Florida. She has lived with him since January 3, 2017. She has no children. She is employed as part-time bartender at The Dunedin Brewery. She earns about $150 per night in unreported tips and under-the-table cash. She also is a housekeeper for a local inn. She works there 25 hours per week earning $10.00 per hour.

Cindy does not drive because her driver's license was revoked after she received a second conviction in 2006 for driving under the influence of alcohol. She has not had any other problems with the law.

Prior to 12/10/20, Cindy was active. She worked her housekeeping job and at the bar 3 nights per week, clearing $300-350 at the bar alone. At that time, she was romantically involved with Scott Summers. Scott had been a regular customer of hers. He was a big tipper and a funny guy. Cindy had never seen anyone hold his alcohol as well as Scott did. He never seemed to get drunk even when he must have been intoxicated. She thought that they were a "great team" until the car accident.

On 12/10/20, they went to Kelly's-The Chic A Boom Room at 9 or 9:30 p.m. to celebrate her birthday. They were drinking shots of Jack Daniels whiskey, playing darts, and pool. Scott had been battling a sinus infection. He told Cindy that shots are the best medicine that he knows. He decided to consult with "Dr. Jack" that evening. After midnight, Scott told her that he felt sick. She felt his forehead. It was hot. She told him, "It's smokin' hot. Let's get you home to work on that fever."

They walked to Scott's car. He was sweating. He did not appear to Cindy to be intoxicated but he did not look well. The sweat was dripping from Scott's brow.

They got into the car. Scott started driving on Route 23. He failed to take the curve and drove over a grassy median. Cindy yelled. Scott reacted by jerking the steering wheel as if he was just waking up. Scott's car struck four parked vehicles before coming to a complete stop. Scott's leg was bleeding and she hit her head on the dashboard.

A police officer came to the scene and arrested Scott for a DUI after his failure to meet minimum standards for field sobriety. Cindy was taken by ambulance to Mease Dunedin Hospital. She was treated in the emergency room. Her diagnoses were head contusion, fractured tibia [broken leg], cervical [neck] sprain, and lumbar [lower back] strain.She received stitches in her forehead at the emergency room. Cindy wore a cast on her left leg for 4-1/2 weeks. She took muscle relaxers and pain medication for 3 weeks. She could not work until the cast was removed.

Cindy's bills are as follows: Mease Dunedin Hospital: $1,575.00; Diagnostic Radiology: $53.00; OrthoDocs Ltd.: $4,500; Emergency Physicians Group: $ 950.00; Walgreens: $55.00.

She now has a 1-1/2" scar on her forehead as well as a 2" scar on her left leg. During the winter her leg seems to ache more. Her activities are not restricted. She has resumed all of her pre-collision activities.

She and Scott grew apart after the incident. They no longer are friends and rarely speak to each other but remain roommates.

Draft a Multi-Count Complaint and Summons to be served on Scott.