Fill and Sign the Boat Injury Form

IN THE ___________ COURT OF _____________ (County) , _____________ (State) ____________________ PLAINTIFF (Name of Plaintiff) V. CAUSE NO. _____,______ ____________________ DEFENDANT (Name of Defendant) Complaint COMES NOW __________________ (Name of Plaintiff) , Plaintiff in the above- styled and numbered cause, by and through his attorney, and files this his Complaint against Defendant, ____________________ ( Name of Defendant) , and in support thereof would show unto the Court the following matters and facts: 1. Plaintiff is an adult resident citizen of _______________________________ (city, county, state) . 2. Defendant is an adult resident citizen of ______________________________ (city, county, state) . 3. On or about _________________ (date) , Defendant was the owner and operator of a boat with a(n) _______ (number) horsepower outboard motor, which were in the __________________ ( name of body of water) near ________________ (name of city) , in County, ______________ (name of state) . 4. On ____________ (date) , at approximately __________ (time) , Defendant was in Defendant's boat and operating it while Plaintiff was in the water, with water skis placed on Plaintiff's feet. 5. At such time and place, while Plaintiff was in the process of adjusting himself to be towed by Defendant in the boat, and while Plaintiff had the tow bar and tow line in Plaintiff's hands, taking up the slack in the line, Defendant, without any signal or warning, negligently, carelessly, and deliberately placed the motor in forward gear and accelerated the boat to a high and dangerous speed, thereby entangling Plaintiff's (specify, such as: left hand and arm and Plaintiff's right hand) _______________ _________________________ in the tow line and causing permanent and lasting injuries to Plaintiff, as more particularly set forth below. 6. The injuries to Plaintiff were caused by the careless, negligent, improper, unskillful, and wrongful conduct of Defendant operating and navigating Defendant's motorboat, for the reason that, contrary to proper care, skill, and caution, Defendant: A. Caused the motorboat to start off without giving any warning or signal to Plaintiff; B. Caused the motorboat to start off without first taking the slack out of the tow line that Plaintiff was holding, contrary to established custom and practice well known to Defendant; C. Caused the motorboat to start off at a high and dangerous rate of speed, the exact speed being unknown to Plaintiff; D. Caused the motor boat to start off without allowing Plaintiff sufficient time to ready himself for being towed or to release the tow line and handle; E. Caused the motorboat to start off without looking to the rear or at Plaintiff to determine whether Plaintiff was prepared for being towed; and F. Ignored the warnings and shouts of protest of ______________________ (names) , who were riding in the boat with Defendant, to stop the boat. 7. As a direct and proximate result of Defendant's negligence, Plaintiff suffered extreme physical pain and mental anguish and will continue to suffer extreme physical pain and mental anguish in the future, for which Plaintiff is entitled to damages from Defendant of $__________. 8. As a further direct and proximate result of Defendant's negligence, Plaintiff suffered (specify injury) _____________________________________________ . 9. As a further direct and proximate result of Defendant's negligence, Plaintiff incurred reasonable and necessary expenses for the services of doctors and nurses, for hospitalization, for ambulance service, and for drugs, in the amount of $__________. 10. Defendant did willfully and with a reckless disregard for Plaintiff's safety, knowing Plaintiff's presence as described above, commit the described acts without attempting in any way to avert injury to Plaintiff. These acts were acts of gross and wanton negligence perpetrated without cause or excuse, in that _________________________ _________________________________________________________ (describe) . WHEREFORE, Plaintiff requests judgment against Defendant for the following: 1. General damages in the amount of $____________; 2. Punitive damages in such amount as will sufficiently punish Defendants for their willful and malicious conduct and as will serve as an example to prevent a repetition of such conduct in the future; 3. Damages for medical and related expenses in the amount of $__________; 4. Interest according to law; 5. Costs of this action; and 6. Such other and further relief as the court deems just and proper. Respectfully submitted, ______________________ (Name of Plaintiff) By: _______________________________ (Name of Plaintiff’s Attorney) State Bar No. _____________ His Attorney OF COUNSEL: ________________________ (Name of Plaintiff’s Attorney) Post Office Box ____________ _____________________________ (City, State, Zip Code) Telephone: _________________