Case Background
Jean Carlo Anguelov Rodriguez lived in Miami-Dade County, Florida. On November 14, 2017, he visited a commercial property located at 3655 NW 78th Avenue in Doral, Florida. APDC Corporation and United Ceramics Corporation owned, operated, or managed the premises. Armando Alvarez and Miguel Angel Crespo worked at the property as agents or employees of these companies. Rodriguez lawfully entered the premises as an invitee.
Cause
While on the property, Rodriguez stood near a stack of plywood sheets. Alvarez instructed Crespo to continue stacking them. As Crespo did so, the plywood collapsed without warning. Rodriguez was crushed beneath the falling sheets. The plaintiff alleged the defendants failed to supervise, guide, or train workers properly. He also claimed they lacked proper equipment and failed to secure the stacked materials. The lawsuit argued this negligence created an unsafe and dangerous condition.
Injury
The collapsing plywood caused Rodriguez serious, permanent injuries. He experienced physical pain and emotional suffering. His injuries included disfigurement, limited mobility, and a worsened pre-existing condition. These injuries disrupted his ability to work and lead a normal life. He continued to suffer long after the incident.
Damages
Rodriguez sought damages exceeding $50,000. He claimed loss of income, reduced earning capacity, and long-term medical expenses. He also demanded compensation for physical and mental pain, anguish, and permanent disability. The complaint included costs for hospitalization, ongoing treatment, and daily limitations.
Key Arguments and Proceedings
Legal Representation
Plaintiff: Jean Carlo Anguelov Rodriguez
Counsel for Plaintiff: Matthew E. Kaplan | Bradley J. Kaplan
Expert Witness for Plaintiff: Gary Anderson | Paul Ramos | Chip Darius | Robert J. Koning
Defendants: APDC Corporation | United Ceramics Corporation | Paseo De Las Artes Corp | Solare Corp | Paseo De Las Artes (AKA) | Paseo De Las Artes II (AKA) | Armando Alvarez | Miguel Angel Crespo a/k/a Miguel Angel Crespo-Suero | Teatro De A Locha Corp | Cultural Alliance for the Presentation of the Arts
Counsel for Defendants: Joseph J. Godberg | Nicholas A. Demahy | Javier Banos Machado | Arthur Spiegel
Expert Witness for Defendant: Edward T. Wolpert
Claims
Rodriguez filed four negligence counts:
Count I: Against APDC Corporation for breaching its duty to maintain a safe premises and supervise employees.
Count II: Against United Ceramics Corporation for failing to ensure safe operations on-site.
Count III: Against Armando Alvarez, who allegedly directed unsafe stacking and failed to manage site safety.
Count IV: Against Miguel Angel Crespo, who performed the stacking and did not secure the plywood.
Rodriguez demanded a jury trial and full compensation for his injuries.
Defense
Defendants Paseo De Las Artes Corp, Teatro De A Locha Corp, Solare Corp, and Cultural Alliance for the Presentation of the Arts denied all substantive allegations in the complaint, admitting only limited jurisdictional facts. They asserted multiple affirmative defenses, including comparative negligence, lack of duty, and the sole negligence of the plaintiff or third parties. They argued the incident resulted from actions outside their control and claimed that if any damages occurred, they were caused by others or due to conditions that were open and obvious.
Additionally, the Defendants asserted that Jean Carlo Anguelov Rodriguez was unlawfully employed at the time of the incident and should be barred from recovery under Florida’s workers’ compensation statutes. They argued his employment status and actions violated immigration and labor laws, making him ineligible to benefit from any resulting injury. Defendants also claimed Rodriguez failed to mitigate damages and that his injuries stemmed from pre-existing conditions or third-party negligence.
Jury Verdict
On May 19, 2025, the jury returned a verdict in favor of Plaintiff Jean Carlo Anguelov Rodriguez against Defendant Armando Alvarez, awarding total damages of $13,327,904. The jury awarded $1,117,411 for past medical expenses and $5,785,493 for future medical expenses. Additionally, they awarded $1,260,000 for past non-economic damages, including pain and suffering, physical impairment, and loss of enjoyment of life, and $5,165,000 for future non-economic damages related to the same.
