West Palm Beach Form Complaint - Automobile Collision - Passenger - Disc injury: Call 1-800-74-TRIAL

Now comes the plaintiff, by and through counsel, who complains against the defendant as follows:
1. The plaintiff, John Jones, is a resident of the City of West Palm Beach, County of Palm Beach, and State of Florida, and to the best of plaintiff’s knowledge, information and belief, the defendant is a resident of the Town of City of West Palm Beach, County of Palm Beach, and State of Florida
2. On or about October 9, 2002, the plaintiff was a passenger in an automobile operated by Mary Smith of Denver, Colorado which had stopped to make a left turn from City of West Palm Beach, County of Palm Beach, and State of Florida
3. At the above mentioned time and place, the defendant, Robert Doe, negligently operated his motor vehicle in such a manner that it struck the rear of the vehicle in which the plaintiff was a passenger with significant force.
4. The defendant was negligent by failing to see the automobile operated by the driver of plaintiff’s vehicle, by operating at a speed that was unsafe for the conditions, by following too close, and by colliding with the vehicle operated by Mary Smith.
5. As a result of the defendant’s negligence, the plaintiff sustained serious and disabling injuries including, but not limited to, injuries to his neck, back, and other parts of his body.
6. As a further result of the defendant’s negligence, the plaintiff sustained injuries which caused surgery to his spine and specifically at the L4-5 level of such spine.
7. As a further result of the defendant’s negligence, the plaintiff incurred substantial medical bills in excess of $20,000 and sustained injuries which caused permanent disability.
8. As a further result of the defendant’s negligence, the plaintiff incurred loss of income and will incur further loss of income into the future.
9. As a further result of the defendant’s negligence, the plaintiff experienced pain and suffering, has lost enjoyment of life, and will continue to experience pain and suffering and loss of enjoyment of life into the future.
10. As a further result of the defendant’s negligence, the plaintiff sustained injuries to his spine which are permanent in nature, sustained permanent impairment, and sustained injuries which will require medical treatment well into the future.
11. At all times relevant to this complaint, the plaintiff was in the exercise of due care as a passenger in the Smith vehicle.
WHEREFORE, the plaintiff prays for judgment against the defendant in an amount which is reasonable and just under the circumstances [in the amount of $200,000] together with interest, costs, and such other and further relief as to this Honorable Court seems just and proper.