Fill and Sign the Complaint Mississippi 497315298 Form

IN THE CIRCUIT COURT OF THE       JUDICIAL DISTRICT OF       COUNTY, MISSISSIPPI       PLAINTIFF V. NO.             DEFENDANT COMPLAINT Comes now the Plaintiff,       , and files this complaint against the Defendant,       , and for cause would show unto the Court as follows, to-wit: I. The Plaintiff is an Adult resident citizen of       County, Mississippi, whose address is       . 1. The Defendant is an adult resident citizen of       County, Mississippi, whose address is       . 2. At all times herein mentioned Defendant,       , was the owner and operator of a       automobile which is the vehicle operated by name defendant driver if different, otherwise type "       in the incident complained of. 3. Skip this paragraph if driver is not an employee of       . On or about date,       , was the agent, servant and employee of said Defendant and was operating the above-mentioned vehicle within the scope of his employment as an employee of       . 4. On the date above mentioned, Plaintiff was operating his or her       automobile in a safe and prudent manner and was proceeding       on       . 5. Skip unless plaintiff was a passenger on the date above mentioned, Plaintiff,       , was a passenger in said vehicle being driven by name driver       in a direction of travel       direction on name of road       . Due to the careless, reckless and negligent actions of name of defendant driver       , said vehicle was involved in a violent collision whereby as a proximate result thereof, Plaintiff sustained severe and disabling injuries. 6. At the time herein complained of, the vehicle was operated by the Defendant who caused briefly describe accident       all of which occurred without fault or negligence on the part of the Plaintiff. 7. In addition to the above mentioned acts of negligence, the collision was caused by one or more of the following acts of negligence on the part of name defendant driver       : a. Failure to yield the right-of-way; b. Failure to keep a proper lookout for other traffic; c. Failure to maintain the proper degree of control of the vehicle; d. Operating the vehicle in an unsafe, unreasonable, reckless or indiscriminate manner without due regard for the safety of others, including the Plaintiff; e. Failure to avoid the collision. 8. As a proximate cause of the negligence of the Defendant, Plaintiff was caused, and will be caused in the future, to suffer the following injuries and damages: a. Medical, doctor, hospital and drug bills both in the past and reasonably anticipated in the future; b. Loss of wage earnings and loss of wage earnings reasonably anticipated in the future; c. Loss of wage earning capacity; d. Permanent and disfiguring disability; e. Severe pain and suffering in the past and the Plaintiff anticipates to experience severe pain and suffering in the future; f. Severe pain and disfigurement and disabling injuries to his or her       body as a whole; g. Deprivation of her or his       ability to enjoy a normal life; h. Mental anguish and shock to her or his       nervous system. WHEREFORE, Plaintiff demands judgment of and from the Defendant, name defendant(s)       , in a sum in excess of the jurisdictional amount of this Court, together with all cost of court and interest from the date of the incident herein complained of. Respectfully submitted this the       day of       , 2       .       By:____________________________________       Attorney for