Fill and Sign the Motor Vehicle Accidents Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF VS. NO.             ,       AND       DEFENDANTS COMPLAINT I. INTRODUCTION 1. This is an action for damages incurred in an automobile accident, which occurred due to the negligence of the defendants. II. JURISDICTION 2. This Court has jurisdiction of this matter pursuant to the Miss. Const. of 1892, 156, and pursuant to Miss. Code. Ann. Section 9 - 7 - 81 as the amount in controversy exceeds       . III. PARTIES 3.       (hereinafter the "Plaintiff") is an adult resident citizen of       County, Mississippi, residing at       , Lot       ,       , Mississippi       . 4.       is a minor resident citizen of       County, Mississippi, and may be served with process of this Court by serving him/her and a copy of the Summons on one of his/her parents listed in the next paragraph 5, below at his residence:       ,       , Mississippi       . 5.       and       are adult resident citizens of       County, Mississippi, and may be served with process of this Court at his/her residence:       ,       , Mississippi       . These two (2) defendants are liable for the negligent driving of       by virtue of the fact that they signed his/her drivers license application and he/she was under the age of       (       ) years at the time of the herein below alleged accident. A true and correct copy of same drivers license application is attached hereto as Exhibit "A" and made a part herein by reference as if copied herein in full. IV. FACTS 6. On or about             ,       , at approximately       a.m./p.m.       was traveling       approaching       . 7. At the aforesaid time,       was traveling       . 8. Upon approaching       and       , the defendants were traveling in the left hand lane of through traffic. Although the defendants had a       light, they proceeded through the intersection. 9. As plaintiff entered the intersection he/she was struck by the vehicle being driven by defendant,       which failed to stop at the red light. 10. At all times herein, the plaintiff had the right - of - way. When the defendant failed to stop at his/her       light and entered       and       , he negligently failed to yield the right - of - way to the plaintiff's truck and the vehicles collided. 11. As a result of the accident,       suffered severe physical injuries including orthopedic and neurological problems, resulting in the need for past and future medical expenses and loss of wages. 12. Plaintiff also sustained pain and suffering and discomfort as a result of the defendant's negligence. V. CAUSE OF ACTION 13. The defendant had a duty to yield the right - of - way to the plaintiff; however, defendant failed to do so. 14. Defendant's negligence proximately caused all of the above - noted damages suffered by the plaintiff. 15. Because of the defendant's breach of duty, the plaintiff seeks recovery for his/her physical injuries, including past and future pain and suffering, permanent scarring and disfigurement, mental anguish, disability and medical expenses in addition to any other damages, past and future, which may be proved at trial. WHEREFORE, PREMISES CONSIDERED, plaintiff seeks judgment of and from the defendants, jointly and severally, in such an amount as to compensate him/her fully for any and all damages sustained as a proximate result of the aforesaid accident, said amount being in excess of       . Respectfully submitted,       ________________________________________ BY:             , Attorney for Plaintiff