Fill and Sign the Sample Separation Agreement Findlaw Form

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.
5. This cause of action was raised and first filed by him in the county court ( in the name of plaintiff) on july 27, 2014, against the above named defendants and a new set of named defendants named above and in support hereof would show unto the court: 1. The name of plaintiff of this lawsuit is 2. His current address in 3. Name, age, occupation, date of birth, and address of his wife. 4. That he owns and to the best of his knowledge has possession ( of said vehicle ) in the same vehicle. 5. That plaintiff maintains service of process against the above and named defendants and has served them in process in this cause of action. A copy of any pleading will also be served on the above and named defendants as may be necessary. 6. On or about the day of the accident, 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. The proximate cause of the accident was the driver's failure to maintain control, failure to provide a proper look out, and excessive speed. For purposes of liability, the question of negligence on the part of the agent and employee will be determined on a jury's verdict. In an interpleader proceeding, the jury may determine a matter of fact by determining if defendant's negligence did cause damages or, if not, how many damages was due to defendant's negligence. (the court may conduct such an examination of the documents and may rely upon the testimony of witnesses at trial and on any evidence or findings of law or the court may find to be sufficient by clear and convincing evidence to establish the facts relied upon. If the court denies the petition, the petition will be dismissed with prejudice.) 7. On or about the day of the accident, plaintiff was operating his vehicle in accordance with the terms and conditions of his driver's license and in compliance with all applicable traffic laws of the state of California, and was not in violation of any traffic laws of the state of California. 8. On or about the day of the accident, plaintiff was the principal operator of the vehicle that was struck and his personal injuries and related damages were caused by the willful and wanton conduct of defendant,, as agent for the owner of defendant's vehicle, and defendant was negligent in violating his duty under section 22671, subdivision (b), in that he, in violation of duty, failed to maintain control of his vehicle and.