Fill and Sign the Alabama Complaint for Slip and Fall Form

IN THE CIRCUIT COURT OF __________ COUNTY, ALABAMA _________________ * * Plaintiff, * * VS. * CIVIL ACTION NO.: * _________________ * CV -_______________ * Defendant. * COMPLAINT COMES NOW Plaintiff ________________________, by and through undersigned counsel, and states as follows: COUNT ON E (Negligence) 1. Plaintiff is a resident citizen of the County of _____________, State of Alabama, and is over the age of twenty -one (21) years. 2. Defendant is______________________________________________________. 3. On or about the _______ day of __ ____________, ________, Plaintiff, while an invitee, was upon the _________________________premises of Defendant in __________________, Alabama, when Plaintiff fell and was injured. 4. Plaintiff’s was caused to fall when [here set out basic facts consti tuting the Defendant’s negligence; also add “with knowledge (or constructive knowledge -here allege the appearance of the object or substance which caused the slip and fall) that a dangerously slippery substance was on the floor of its store, Defendant allo wed said substance to remain there without cleaning it up and without warning Plaintiff of the presence of the substance or the danger that it posed”]. 5. As a proximate result of the Defendant’s said negligence, the Plaintiff was caused to suffer the fol lowing injuries and damages: [here set out injuries and damages]. WHEREFORE, Plaintiff demands judgment against Defendant in excess of the jurisdictional limits of the court for compensatory damages, interest, and costs. COUNT TWO (Wantonness) 6. Plaintiff adopts and realleges the allegations contained in paragraphs 1 through 5, above. 7. Plaintiff restates those allegations in COUNT ONE except that Plaintiff substitutes the word “wanton” for the word “negligent”, and the words “wantonness and wan tonly” for the words “negligently and negligence”. 8. As a proximate result of the Defendant’s said wantonness, the Plaintiff was caused to suffer the damages [and injuries] as set out in paragraph 5 of this complaint. WHEREFORE, Plaintiff demands judgm ent against Defendant in excess of the jurisdictional limits of the court for compensatory and punitive damages, interest, and costs. _____________________________________________ (Attorney for Plaintiff) PLAINTIFF RESPECTFULLY REQUESTS A TRI AL BY JURY AS TO ALL COUNTS HEREIN __________________________________________ (Attorney for Plaintiff) PLEASE SERVE DEFENDANT AS FOLLOWS: [BY CERTIFIED MAIL] [BY PROCESS SERVER] [BY LOCAL SHERIFF’S DEPT.] __________________________________ ______ ____________________________