Florida Complaint in Auto/Pedestrian Case: Call 1-800-74-TRIAL

Now comes the plaintiff, by and through counsel, who complains against the defendant as follows:
1. The plaintiff, Tom Jones, is a resident of the City Lake Worth, County of Palm beach, State of Florida at all times relevant to this complaint.
2. The defendant, Sarah Doe, is a resident of City Lake Worth, County of Palm beach, State of Florida
3. On or about October 15, 2002, the plaintiff was crossing Congress Street at the intersection of Congress and High Street in the City City Lake Worth, County of Palm beach, State of Florida
4. The plaintiff was lawfully crossing the street in a crosswalk with a walk light indicating “WALK” at the time of the incident which is the subject of this claim.
5. At the above mentioned time and place, the defendant negligently failed to yield to the plaintiff who was lawfully in a crosswalk and walking with a “WALK” light when the defendant made a right-hand turn from High Street onto Congress Street.
6. The defendant negligently struck the plaintiff causing the plaintiff to be catapulted ten or fifteen feet through the air landing with significant force on Congress Street.
7. The defendant was negligent by failing to yield to the pedestrian who was lawfully in a crosswalk, by failing to see the pedestrian in broad daylight, by driving too fast for conditions, and by failing to keep a proper lookout for pedestrians and other vehicles.
8. As a result of the defendant’s negligence, the plaintiff incurred injuries including, but not limited to, a fractured ankle, arm injuries, lacerations and abrasions caused by the automobile/pedestrian contact.
9. As a further result of the defendant’s negligence, the plaintiff incurred medical bills, will incur medical bills in the future, sustained loss of income, and will sustain further loss of income into the future.
10. As a further result of the defendant’s negligence, the plaintiff incurred pain and suffering and will incur further pain and suffering and probable permanent injuries into the future.
11. At all times relevant to this complaint, the plaintiff was in the exercise of due care by lawfully walking within a crosswalk and with the “WALK” light in her favor.
WHEREFORE, the plaintiff prays for judgment against the defendant in an
amount which is reasonable and just under the circumstances, together with interest, costs and such other and further relief as to this Honorable Court seems just and proper.