Fill and Sign the Personal Injury Fell on Concrete Steps Mississippi Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF VS. NO.             DEFENDANT COMPLAINT COMES NOW       and for cause of action against       alleges as follows: I. Plaintiff       is an adult resident citizen of       County, Mississippi, and resides at       ,       ,       County, Mississippi. II. Defendant is a Mississippi Corporation and has as its registered agent for service of process       who may be served with process at       ,       ,       County, Mississippi       . III. Plaintiff       alleges that on or about             ,       , he/she was exiting the       on       ,       , Mississippi. Said building is owned, occupied and managed by Defendant. As Plaintiff stepped down from the concrete steps in front of said building, he/she caught the heel of his/her shoe in a crack in the concrete, causing his/her to fall and sustain serious, painful and permanent injuries as hereinafter described. Said crack was higher on one side than the other side, which was deceptive in appearance, and the uneven height contributed to the cause of Plaintiff's fall. IV.       a.       b. Negligent failure to warn individuals such as Plaintiff of the hazardous and dangerous condition which then and there existed, which was known or should have been known by defendant. c. Failure to maintain the steps in a reasonably safe condition; d. Failure to provide a handrail, e. Other acts of negligence to be shown at trial, which may be learned through discovery. VI. Plaintiff       alleges that as a result of the negligence of the Defendant, and the aforesaid accident, the Plaintiff sustained a       , and as a result thereof had to have surgery and a steel       inserted. Medical bills thus far have exceeded $       . Plaintiff has had to endure grievous pain and suffering as a result of his/her injury, continues to suffer with his/her injury at this time, and reasonably believes that he/she will suffer permanently from his/her injuries. In addition, Plaintiff reasonably believes that he/she will require medical treatment in the future for the treatment of said injuries. Plaintiff has suffered permanent disability as a result of his/her injuries, and will never enjoy the health he/she enjoyed prior to the subject accident. All such damages are as a result of the negligence of Defendant. VII. Plaintiff alleges that the negligent acts of the Defendant were the proximate cause or the proximate contributing cause of the Plaintiff's accident and injuries. WHEREFORE, PREMISES CONSIDERED, Plaintiff sues and demands judgment of and from       in the amount of $       . Respectfully submitted, _______________________________________       Attorney for       Of counsel:                         Telephone:       MSB #       Attorney for