Complaint for Negligence

COMPLAINT

IN THE CIRCUIT COURT OF COUNTY,

VS.

COMPLAINT

Comes now the Plaintiff , by and through its counsel, and files this its complaint against Defendant , and would show unto the court the following matters and facts to-wit:

1. Plaintiff (herein after " ") is a corporation, the principal place of business of which is , , .

2. Defendant is an adult resident of County, , who may be served with process at , , .

3. On or about Wednesday, , the Defendant, , without possessing either a driver's license or automobile insurance, drove the car of the Defendant, his aunt, to the Convenience Store No. located at , . At said time and place, Defendant , acting in a negligent, grossly negligent and reckless manner, drove his vehicle through the front of , causing extensive damage to said building.

4. The accident which occurred was due solely to the following negligent, grossly negligent, reckless and/or illegal acts of the Defendant:

A. Defendant failed to keep the vehicle he was driving under adequate and proper control.

B. Under the circumstances then existing, Defendant operated the vehicle with reckless and wanton disregard for others.

C. Defendant violated the laws and traffic regulations of the State of , specifically the following sections of the Code Ann. (Rev. & Supp. ):

§ . License required to operate vehicles.

No person shall drive or operate a motor vehicle other than a motorcycle upon the highways of the State of without first securing an operator's license to drive on the highways of the state, except those persons especially exempted by Section .

§ . License to be carried and exhibited on demand.

Every licensee shall have the required license in his immediate possession at all times when operating a motor vehicle and shall display the same, upon demand of a justice court judge, a peace officer or license examiner or other authorized employee of the commissioner. However, no person charged with violating this section shall be convicted if he produces in court a license theretofore issued to him and valid at the time of his arrest.

§ . Reckless driving.

Any person who drives any vehicle in such a manner as to indicate either a wilful or a wanton disregard for the safety of persons or property is guilty of reckless driving. Reckless driving shall be considered a greater offense than careless driving.

Every person convicted of reckless driving shall be punished upon a first conviction by a fine of not less than Dollars ($ ) nor more than Dollars ($ ), and on a second or subsequent conviction he may be punished by imprisonment for not more than ( ) days or by a fine of not exceeding Dollars ($ ), or by both.

§ . Careless Driving.

Any person who drives any vehicle in a careless or imprudent manner, without due regard for the width, grade, curves, corner, traffic and use of the streets and highways and all other attendant circumstances is guilty of careless driving. Careless driving shall be considered a lesser offense than reckless driving.

Every person convicted of careless driving shall be punished by a fine of not less than Dollars ($ ) nor more than Dollars ($ ).

D. As a direct and proximate result of the aforesaid negligence, gross negligence, recklessness and other misconduct of Defendant, No. sustained heavy damages in the amount of $ .

Accordingly, Plaintiff prays for judgment against Defendant in the amount of ($ ) in actual damages, and punitive damages of ($ ), in addition to all attorney's fees and costs incurred herein.

This the day of .