Palm Beach County Florida Automobile Accident Complaint With Loss of Consortium Claim

SUPERIOR COURT FOR THE STATE OF _______________
COUNTY OF _______________

PLAINTIFF AND PLAINTIFF’S :
SPOUSE :
:
vs. : C.A. No. __________
:
DEFENDANT :

COMPLAINT

1. Plaintiff is a resident of the Town of (city/town), County of (county), State of (state).

2. Plaintiff’s spouse is also a resident of the Town of (city/town), County of (county), State of (state) and, at all times material hereto, was Plaintiff’s legal spouse.

3. Defendant is a resident of the Town of (city/town), County of (county), State of (state).

4. The amount in controversy exceeds the jurisdictional requirements of this Court and venue is proper in this Court in that this action arose within in (county and state).

COUNT I

5. On or about (date) at approximately (time) Plaintiff was driving a motor vehicle on a public highway known as Park Avenue.

6. At that time and place, Defendant negligently operated a motor vehicle causing it to strike Plaintiff’s vehicle.

7. Defendant owed Plaintiff a duty to exercise reasonable care in the operation of his vehicle. Defendant breached his duty in that he failed to operate his vehicle in a safe and reasonable manner.

8. As a direct and proximate result of the Defendant’s breach of duty, Plaintiff suffered severe injuries and damages, including, but not limited to, physical and emotional injuries, costs of medical treatment for such injuries, loss of earning capacity, loss of earnings, pain and suffering, and other consequential damages.

WHEREFORE, Plaintiff demands judgment against Defendant in an amount which exceeds the jurisdiction, requirements of this Court, plus interest and costs and further demands such other and further relief as this Court may deem just, proper and equitable.

COUNT II

9. The allegations set forth in paragraphs 1 through 8 are incorporated herein as if set forth again in full.

1O. As a direct and proximate result of the Defendant’s negligence, Plaintiff’s Spouse lost the care, comfort, society, consortium, companionship and services of her husband, Plaintiff, has been injured thereby, and is entitled under law to recover against Defendant for these losses.
WHEREFORE, Plaintiff Spouse demands judgment against Defendant in an amount which exceeds the jurisdictional requirements of this Court, plus interest and costs; and further demands such other and further relief as this Court may deem just, proper and equitable.

Plaintiff and Plaintiff Spouse
By Their Attorneys,

PLAINTIFF AND PLAINTIFF’S SPOUSE DEMAND A TRIAL BY JURY ON ALL ISSUES TRIABLE OF RIGHT BY A JURY IN THE WITHIN ACTION.

Plaintiff and Plaintiff’s Spouse
By Their Attorneys,