Fill and Sign the Auto Accident Negligence Form

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [ INSERT CAPTION ] COMPLAINT (NEGLIGENCE-AUTOMOBILE-GUEST PASSENGER VS. BOTH DRIVERS) COMES NOW the Plaintiff, [ insert name of plaintiff ], by counsel, and for his (or her) Complaint against the Defendants, [ insert name of defendant s], alleges and states PARTIES 1. The Plaintiff, [ insert name of plaintiff ], (hereinafter referred to as the Plaintiff), at all times relevant hereto, is an adult citizen of the State of [ insert state jurisdiction] and resides in [ insert county name ]. 2. The Defendant, [ insert name of driver #1 ], (hereinafter referred to as Defendant "), at all times relevant hereto, is an adult citizen of the State of [ insert state jurisdiction] and resides in [ insert county name ]. 3. The Defendant, [ insert name of driver #2 ], (hereinafter referred to as Defendant #2"), at all times relevant hereto, is an adult citizen of the State of [ insert state jurisdiction] and resides in [ insert county name ]. FACTS 4. On or about [ insert date ] the Plaintiff was a guest passenger in an [ insert description of vehicle ] automobile being operated by Defendant #1 on [ insert name of roadway, direction of travel and the nearest intersection or traffic control device or other landmark ], which said roadway is a: [ insert description of roadway and traffic control, e.g., 2 or 4 lane roadway, north and south directions, stop lights or stop signs, etc. ]. At said time and place the road and weather conditions were: [ insert road and weather conditions at time of accident ]. - 1 - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5. At said time and place, Defendant #2 was operating a [ insert description of vehicle ] automobile on insert name of roadway, direction of travel and the nearest intersection or traffic control device or other landmark ], which said roadway is a: [ insert description of roadway and traffic control, e.g., 2 or 4 lane roadway, north and south directions, stop lights or stop signs, etc. ]. 6. At said time and place, Defendant # 1 operated his automobile in a negligent and careless manner by: operated his automobile in a careless and negligent manner by: [ insert description of violation of traffic laws, rules, regulations, rules of the road, etc., e.g., failure to yield right-of-way, failure to keep a proper look out, speeding, failure to keep vehicle under proper control, intoxication, etc. ]. 7. At said time and place, Defendant # 1 operated his automobile in a negligent and careless manner by: operated his automobile in a careless and negligent manner by: [ insert description of violation of traffic laws, rules, regulations, rules of the road, etc., e.g., failure to yield right-of-way, failure to keep a proper look out, speeding, failure to keep vehicle under proper control, intoxication, etc. ]. 8. At said time and place, At said time and place, the automobiles being operated by Defendant #1 and Defendant #2 collided causing the Plaintiff to sustain: [ insert the types of damages, e.g., severe & permanent personal injuries; past, present & future pain & suffering; past, present & future mental anguish; loss of enjoyment of life’s activities; permanent or temporary partial/total disability; lost wages, lost or diminished earning capacity, past, present & future medical bills and expenses; etc.]. CLAIMS 9. The Defendants, and each of them, had a duty to: [ insert traffic statutes, rules, regulations, & ordinances ]. 10. The Defendants, and each of them, breached the duties delineated - 2 - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 hereinabove proximately causing or proximately contributing to the cause of the collision and Plaintiff’s damages alleged herein. DEMAND FOR RELIEF 11. The Plaintiff prays for the following relief: (1) Trial by jury; (2) Judgment for Plaintiff and against Defendants, jointly and severally; (3) An award of damages which will fully and fairly compensate Plaintiff for [ insert the types of damages, e.g., severe & permanent personal injuries; past, present & future pain & suffering; past, present & future mental anguish; loss of enjoyment of life’s activities; permanent or temporary partial/total disability; lost wages, lost or diminished earning capacity, past, present & future medical bills and expenses; etc.]. (4) Such other and further relief deemed just and proper in the premises. - 3 -