Fill and Sign the Wrongful Death Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       ,       ,       ,       ,       ,       ,       , INDIVIDUALLY AND AS PERSONAL REPRESENTATIVES OF THE ESTATE OF       , DECEASED PLAINTIFFS VS. NO.             DEFENDANT COMPLAINT The Plaintiffs, by and through their attorneys, file this their Complaint, and in support of their claims against the Defendant, would show unto the Court the following: 1. The names and addresses of the Plaintiffs, along with their relationship to the decedent are as follows: a)       ,       ,       b)       ,       ,       c)       ,       ,       d)       ,       ,       e)       ,       ,       f)       ,       ,       g)       ,       ,       2. The Defendant,       , is an adult resident citizen of       County, Mississippi and may be served with process of this Court at the       County Jail. 3. The Plaintiffs' claims against the Defendant arose and accrued in       County Mississippi. COUNT I. 4. On or about             ,       , the Defendant wrongfully, intentionally, and/or negligently shot the decedent,       , numerous times with a       . 5. As a direct and proximate result of said wrongful action, the decedent,       , died. 6. If the death of       had not occurred,       would have been entitled to maintain an action and recover damages in respect of the wrongful actions of the Defendant. 7. The wrongful actions of the Defendant as described above proximately caused the death of       , whose personal representatives are entitled to recover monetary damages from the Defendant. COUNT II. 8. The Plaintiffs incorporate by reference each and every averment made in the paragraphs above. 9. As a direct and proximate result of the wrongful actions of the Defendant as described above, the Plaintiffs have lost the consort, society, companionship, affection, income services, and support of       and have suffered mental anguish and emotional distress because of the injury and death of       . 10. The wrongful actions of the Defendant as described above proximately caused the injuries suffered by the Plaintiffs who are entitled to recover monetary damages from the Defendant. COUNT III. 11. The Plaintiffs incorporate by reference each and every averment made in the paragraphs above. 12. The wrongful actions of the Defendant were willful and/or grossly negligent and were so wanton as to show a disregard for the safety of others, thus giving rise to an award of punitive damages against the Defendant. WHEREFORE, the Plaintiffs demand judgment of and from the Defendant in the sum of at       Dollars ($       ) actual damages and       Dollars ($       ) punitive damages, together with reasonable attorney's fees and all costs of Court herein. Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for