Palm Beach County, Florida Automobile Accident Complaint—Closed Head Injury

SUPERIOR COURT FOR THE STATE OF _______
COUNTY OF ________
JOHN SMITH,
Plaintiff

v. C.A. No. ______

HENRY JONES,
Defendant.

COMPLAINT

1. Plaintiff, John Smith (“Smith”), is a resident of (city/town), County of (county), State of (state).

2. Defendant, Henry Jones (“Jones”), is a resident of (city/town), County of (county), State of (state).

3. The amount in controversy satisfies the jurisdictional requirements of this Court and venue is proper in this Court as this action arose within (county and state or other applicable basis for venue).

COUNT I

4. Smith incorporates by reference paragraphs 1 through 3 above as if set forth again in full.

5. On or about (date), at approximately (time), Smith was the driver of a motor vehicle (the “Smith Vehicle”), traveling east on Broad Street in the City of (city).

6. At that time and place, Jones negligently operated a motor vehicle he owned and operated (the “Jones Vehicle”) so as to cause it to collide with the Smith Vehicle.

7. Jones owed Smith a duty to exercise reasonable care in the operation of the Jones Vehicle and Jones breached that duty when he failed to operate the Jones Vehicle in a safe, reasonable and prudent manner.

8. As a direct and proximate result of Jones’ breach of duty, Smith sustained severe injuries and damages including injuries to the brain and spinal cord, resulting in a variety of closed head injuries such as concussion and contusion, and also sustained damages to the cervical and lumbar spine, as well as other physical and emotional injuries, the costs of medical treatment for those injuries, a loss of earning capacity, loss of earnings, pain and suffering, and other consequential damages.

WHEREFORE, Smith demands judgment against Jones in an amount that exceeds the jurisdictional requirements of this Court plus interest and costs and such other and further relief as the Court may deem just, proper and equitable.

PLAINTIFF, JOHN SMITH
By his attorneys,

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Plaintiff, John Smith, demands a trial by jury on all issues triable by right of jury in the within action.

PLAINTIFF, JOHN SMITH
By his attorneys,

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