Fill and Sign the Complaint Regarding Airplanes Form

IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________       ) )       ) Petitioner/Plaintiff, ) ) ) NO.       Vs. ) )       ) Respondent/Defendant ) ) COMPLAINT (JURY TRIAL REQUESTED) COMES NOW, Plaintiff, ____________________, by and through counsel, and files this his Complaint and in support thereof would show unto the Court the following: 1. Plaintiff is an adult resident citizen of ______________ County, _____________. 2. Defendant, ____________________, is an adult resident citizen of ____________ County, ______________. 3. a. Defendant, ____________________, is a ______________ corporation which owned and operated the private plane involved in the accident hereinafter described. b. Defendant, ____________________, is a ______________ corporation which owned and operated the private plane involved in the accident herein described. c. Defendant, ____________________ is an adult resident citizen of the State of ______________ who owned and operated the private plane involved in the accident herein described. - 1 - 4. At all times relevant hereto, Defendant, ____________________, was the pilot of the private plane involved in the accident hereinafter described and was an agent of Defendants, ____________________, ____________________, ____________________, and ____________________. 5. On or about ______________ Plaintiff, ____________________, and other employees of ____________________ flew on a private plane from ______________, to ____________, in order that the Plaintiff might pick up a vehicle owned by _________________ and drive it to another location. When Plaintiff approached the landing field in ____________, Defendant, ____________________, negligently and carelessly failed to lower the landing gear, causing the plane to impact the runway in a violent manner and causing Plaintiff's head to strike the ceiling of the plane. 6. At all times relevant hereto, the Defendants negligently and carelessly maintained and operated the airplane in which Plaintiff was a passenger. As a direct and proximate result of this negligence and carelessness, Plaintiff received serious personal injuries some of which are permanent. As a result, Plaintiff suffers continuous physical pain and mental distress and suffers a permanent diminished capacity to enjoy life. The negligence exhibited by all Defendants causing the accident consists of a reckless and willful disregard for the rights and safety of Plaintiff and others and entitle Plaintiff to punitive damages. 7. Plaintiff is entitled to damages against all Defendants to compensate him for medical bills for treatment and care both past and future. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays for judgment against Defendants in the amount of $_______________ compensatory damages and $_______________ exemplary damages. THIS, the ____________ day of ____________ 20___. - 2 - Respectfully submitted, Dated: Name: Title: Address: Address: City, State, Zip: Phone: Fax: E-Mail: Attorney No.: CERTIFICATE OF SERVICE I, ______________________________, do hereby certify that I have this day mailed, U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing to __________________________________, at the following address; ___________________________________________________________________ THIS the ____ day of _____________, 20____. _________________________________ - 3 -