Fill and Sign the Demand Jury Form

JOHN LAWYER, ESQ. 12 MAIN STREET ANYWHERE, USA Attorney for Plaintiffs -------------------------------X JANE SMITH AND JOHN SMITH : SUPERIOR COURT OF NEW JERSEY her husband, : LAW DIVISION : MONMOUTH COUNTY Plaintiffs, : : DOCKET NO. vs. : : ABC MALL, 123 INC. : COMPLAINT AND DEMAND JOHN DOES 1-5 (Fictitious names : FOR TRIAL BY JURY as true identities are unknown) : and XYZ CORPORATION 1-5 : (Fictitious name as true : identities are unknown), : : Defendants. : -------------------------------X Plaintiffs, Jane Smith and John Smith, her husband, residing at [insert address], by way of Complaint against the defendants, say: FIRST COUNT 1. On or about [insert date], plaintiff, Jane Smith, was on the sidewalk outside of the ABC Mall, located in the [insert address]. 2. Defendant, ABC Mall, 123 Inc. and/or XYZ CORPORATION, either owned, leased, rented and/or was responsible for managing, controlling, inspecting, maintaining, cleaning and/or repairing the aforesaid premises, as well as keeping the premises free of dangerous and hazardous conditions. 3. Defendants negligently and carelessly operated, managed, controlled, inspected, maintained, cleaned and/or repaired said premises and failed to keep said premises free of dangerous and hazardous conditions. 4. As a direct and proximate result of Defendants' negligence, Plaintiff was caused to fall and sustain injuries of a personal, economic and emotional nature. WHEREFORE, Plaintiff, Jane Smith, demands judgment against Defendants, jointly and/or severally, for damages along with interest, cost of suit, and attorneys fees. SECOND COUNT 1. Plaintiff repeats and realleges all of the allegations set forth in the First Count as if set forth at length herein. 2. Plaintiff is unsure of the true names and capacities of certain defendants and therefore sues them under the fictitious names, "John Does". When Plaintiff has ascertained the true names and identities of said Defendants, she will amend her complaint to so indicate. 3. Said "John Doe" Defendants were careless and negligent in that they carelessly and negligently managed, controlled, inspected, maintained, cleaned and/or repaired the subject premises and allowed a dangerous and hazardous condition to exist which was a direct and proximate result of Plaintiff's injuries. WHEREFORE, Plaintiff, Jane Smith, demands judgment against the defendants, jointly and/or severally, for damages along with costs of suit, interest, and attorneys fees. THIRD COUNT 1. Plaintiff, John Smith, repeats and realleges each and every allegation of the First and Second Counts of the Complaint as if same were set forth at length fully herein. 2. Plaintiff, John Smith, was at all times relevant herein, and still is the husband of Plaintiff, Jane Smith. 3. As a result of the injuries caused to Plaintiff, Jane Smith, which resulted from the negligence of the Defendants. Plaintiff, John Smith, has been caused to suffer the loss of services and consortium of Plaintiff, Jane Smith. WHEREFORE, Plaintiff, John Smith, demands judgment against Defendants, jointly and/or severally, for damages, along with costs of suit, interest, and attorneys fees. JURY DEMAND Plaintiffs hereby demand a trial by jury as to all issues. DESIGNATION OF TRIAL COUNSEL John Lawyer, Esq., is hereby designated as trial counsel in this matter. CERTIFICATION I hereby certify pursuant to Rule 4:5-1 that this matter is not the subject of any other action pending in any Court or of a pending arbitration proceeding, and that there exist no other parties to be joined to this action. __________________________ JOHN LAWYER DATED: ____________