Fill and Sign the In the County Court of the Judicial District of Form

1 IN THE COUNTY COURT OF THE ____________ JUDICIAL DISTRICT OF _____________ COUNTY, ____________ ___________________________________ PLAINTIFF VS. CIVIL ACTION NO. __________________ ____________________________________ DEFENDANT COMPLAINT (Jury Trial Requested) COMES NOW the Plaintiff, _____________________, hereinafter referred to as "_________," and files this, his Complaint, against the Defendant, _______________________, hereinafter referred to as "_________," and in support thereof, would show unto the Court the following matters and facts, to-wit: 1. The Plaintiff _______________ is an adult resident citizen of _______________ County, ____________ 2. The Defendant, is a legal entity organized and existing under the laws of the St ate of ____________ and may be served with process by serving ____________ Executive Director,____________, at ______________, __________,____________, or by mail at Post Office Box _______, ______________. 3. At approximately ________ p.m. on ________, _______ ___, 20___, while going to retrieve his luggage from a _____________flight from _______, ______, _______________ slipped on one of the flights of stairs leading to the first floor of the Airport operated by _______________, ___________________( A_______ ). 2 4. At about ___ A.M. the next day, _______________ awoke with excruciating pain in his neck. _______________ went to see ________________-, as soon as he opened his clinic at about ____________for diagnosis and treatment. In addition to injuring his neck, _______________ injured his lower back and developed weakness in his right hand that ______________said was related to his fall. _______________ also has experienced pain shooting from his right shoulder to his right hand. 5. That at the time of his fall, the stairs were extremely wet and slippery a nd there was no sign that warned of the wet condition of the stairs. It had been raining in ________ and people from outside had come inside and water had dripped from their shoes, coats and/ or umbrellas onto the stairs. It was not raining at the time _______________ fell. 6. _______________, as the operator of a public airport, owed to _______________ a duty to exercise the highest degree of care regarding his safety while in the ________ and using the stairs to the first floor of the ___________, and at all other times during which _______________ was lawfully using _________ facilities. 7. Defendant, in breach of the duty described above, negligently failed to: A. Properly maintain the steps on which Plaintiff fell; B. Remove water from the step on which Plaintiff fell when Defendant knew, or in the exercise of reasonable care should have known, that the stairs were wet and slippery; C. Warn Plaintiff of the dangerous and hazardous condition of the steps on which Plaintiff fell, which condition Defendant knew or should have known about; and D. Otherwise exercise due care with respect to the matters alleged in this 3 Complaint. 8. As a direct and proximate result of the negligence of Defendant as described above, Plaintiff suffered bodily injury and resulting pain and suffering, disability; mental anguish; loss of capacity for the enjoyment of life; medical expenses, loss of earnings; t emporary loss of ability to earn money; and aggravation of a known or unknown previously condition. WHEREFORE, PREMISES CONSIDERED , Plaintiff does hereby demand judgment against _______________ in the amount of $__________ regarding actual damages and $___________ in punitive damages, plus reasonable attorneys  fees and court costs. Respectfully submitted, __________________________ ___ No. ____________ __________________________ Attorney at law____________________________________________________ Telephone - ________________ Telefax - ___________________