Fill and Sign the Sample Complaint for Damages Form

IN THE CIRCUIT COURT OF ___________________ COUNTY, ______________ ___________________. PLAINTIFFVS.NO. ______________________________________ DEFENDANTS COMPLAINT Comes now the Plaintiff ___________________., by and through its counsel, and files this its complaint against Defendant ___________________, and would show unto the court the following matters and facts to-wit: 1.Plaintiff ___________________. (herein after " ___________________") is a ______________ corporation, the principal place of business of which is ___________________, ___________________, ___________________.2.Defendant ___________________ is an adult resident of ___________________ County, _____________, who may be served with process at ___________________, ___________________, ___________ .3.On or about Wednesday, ___________________, the Defendant, ___________________, without possessing either a driver's license or automobile insurance, drove the car of the Defendant, ___________________ his aunt, to the ___________________ Convenience Store No. ___________________ located at ___________________, __________. At said time and place, Defendant ___________________, acting in a negligent, grossly negligent and reckless manner, drove his vehicle through the front of ___________________, causing extensive damage to said building. 4.The accident which occurred was due solely to the following negligent, grossly negligent, reckless and/or illegal acts of the Defendant: A. Defendant ___________________ failed to keep the vehicle he was driving under adequate and proper control. B. Under the circumstances then existing, Defendant ___________________ operated the vehicle with reckless and wanton disregard for others. C. Defendant ___________________ violated the laws and traffic regulations of the State of ____________, specifically the following sections of the _____ Code Ann. (Rev. ____ & Supp. ____): §_____. License required to operate vehicles . No person shall drive or operate a motor vehicle other than a motorcycle upon the highways of the State of __________ without first securing an operator's license to drive on the highways of the state, except those persons especially exempted by Section ______.§_____. License to be carried and exhibited on demand. Every licensee shall have the required license in his immediate possession at all times when operating a motor vehicle and shall display the same, upon demand of a justice court judge, a peace officer or license examiner or other authorized employee of the commissioner. However, no person charged with violating this section shall be convicted if he produces in court a license theretofore issued to him and valid at the time of his arrest. §______. Reckless driving. Any person who drives any vehicle in such a manner as to indicate either a wilful or a wanton disregard for the safety of persons or property is guilty of reckless driving. Reckless driving shall be considered a greater offense than careless driving. Every person convicted of reckless driving shall be punished upon a first conviction by a fine of not less than _____ Dollars ($____) nor more than ________ Dollars ($______), and on a second or subsequent conviction he may be punished by imprisonment for not more than ___ ( __) days or by a fine of not exceeding ____________ Dollars ($______), or by both. §_______. Careless Driving. Any person who drives any vehicle in a careless or imprudent manner, without due regard for the width, grade, curves, corner, traffic and use of the streets and highways and all other attendant circumstances is guilty of careless driving. Careless driving shall be considered a lesser offense than reckless driving. Every person convicted of careless driving shall be punished by a fine of not less than _____ Dollars ($_____) nor more than ____ Dollars ($_____). D. As a direct and proximate result of the aforesaid negligence, gross negligence, recklessness and other misconduct of Defendant, ___________________ No. ___________________ sustained heavy damages in the amount of $___________________. Accordingly, Plaintiff ___________________ prays for judgment against Defendant ___________________ in the amount of ___________________ ($___________________) in actual damages, and punitive damages of ___________________ ($___________________), in addition to all attorney's fees and costs incurred herein. This the _____ day of ___________________ . Respectfully submitted,___________________.By:_____________________________________________________Bar No. ___________________OF COUNSEL:_________________________________________________________Telephone No. ___________________