Fill and Sign the Arthur V King Case No 207 Cv 319 Wkwcasetext 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 ONE(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 a corporation, organized and existing under the laws of the State of ___________, and engaged in the business of issuing insurance policies. 3.On or about the ____ day of ______________, _______, the Defendant issued a policy of automobile insurance to Plaintiff [or to other party, Plaintiff’s ______________ (relationship)], which included uninsured motorist coverage. A copy of said policy is attached hereto as Exhibit A.4.On or about the ____ day of ______________, _______, in ______________ County, Alabama, Plaintiff was injured in a collision with a vehicle negligently operated by ________________ [or by person whose identity is unknown to Plaintiff] who was at that time an uninsured motorist [or who is believed to have been at that time an uninsured motorist].5. As a proximate result of the negligence of said uninsured motorist, Plaintiff was caused to suffer and incur the following injuries and damages: [set out injuries and damages]. WHEREFORE, Plaintiff demands judgment against Defendant in excess of the jurisdicitonal limits of this 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 wantonly” for the words “negligently and negligence”. 8. As a proximate result of the wantonness of said uninsured motorist, Plaintiff was caused to suffer and incur the injuries and damages as set forth in paragraph 5 of this Complaint.WHEREFORE, Plaintiff demands judgment against Defendant in excess of the juridictional limits of this court for compensatory and punitive damages, interest, and costs. _____________________________________________(Attorney for Plaintiff) PLAINTIFF RESPECTFULLY REQUESTS A TRIAL 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.]____________________________________________________________________