Legal considerations for fire and emergency services 3rd edition form
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IN THE COUNTY COURT OF ____________ COUNTY, ___________ NAME OF PLAINTIFF ) )) V. ) NO. )) NAME OF DEFENDANT ) )) COMPLAINT COMES NOW ______________ Plaintiff, by and through counsel and files this Complaint against the Defendant, ___________, and in support hereof would show unto the Court the following: 1. Plaintiff is a resident citizen of _______________County, __________________, and Defendant is a _____________ corporation, which may be served with process by serving its agent for service of process, ______________________. 2. On or about the _________ day of _______________ Defendant's vehicle, operated by Defendant's agent and employee ___________, struck the rear of Plaintiff's car causing damages to said vehicle. 3. Defendant's agent and employee was negligent in the operation of Defendant's vehicle by failing to maintain control, failing to provide a proper look out, and excessive speed. All of Defendant's negligence was the proximate cause of the accident and the proximate cause of Plaintiff's damages. 4. Plaintiff has incurred $___________ in repairs to his vehicle and has suffered approximately $_______________ in depreciation to Plaintiff's vehicle.
(1 ) the accident occurred at 8:43 on the day o october 6, 2012, at intersection of road and , the road being named as part of the roadway. 3 ) at the time of the accident plaintiff was the rear passenger in the car driven by , , defendant driver. 4 ) defendant's agent was a police officer with the Springfield police department. 5) defendant was driving a gray motor vehicle owned by an owner named 5) defendant was driving about the speed limit of miles per hour. 6) the plaintiff had a green traffic signal and no flashing red light, no siren, no rear-end collision warning device, no flashing left turn arrow , and no signs indicating a left turn, no right turn, and no stop sign. 7) the plaintiff's vehicle was parked on the right side of the roadway facing onto road , a road being named as part of the roadway. 8) plaintiff's car was traveling north on road when he observed the defendant's gra motor vehicle going north on road . 9) plaintiff stated that he witnessed the defendant's motor vehicle being seen turning in his rearview mirror while the plaintiff's motor was on the left side of the roadway. 10) defendant was traveling north on road. 11) during the time the plaintiff was being overtaken and rear-ended by the defendant's motor vehicle, he did nothing wrong, neither did the plaintiff take any action to avoid the contact, nor did the plaintiff attempt to swerve out of the way of the defendant's motor. 12) the defendant's motor was traveling at a speed of miles per hour, while the plaintiff's motor was driving between 27 (1) miles per hour and 40 miles per hour at a speed of, 28, 29, 32, 33, 34, 35, and 36 miles per hour, (2) while the plaintiff's motor was traveling between 27, 28, 29, 31, 32, 33, 34, 35, 37, and 38 miles per hour, and the traffic did not stop or slow down to avoid the collision. 13) defendant drove the road at a speed of miles per hour. 14) the road was well-traveled, with signs indicating it as a right-hand turn only roadway, and as such did not impede the defendant's use of this roadway for travel. 15) while the plaintiff, while being overtaken and
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