West Palm Beach car accident Plaintiff ’s Motion for Directed Verdict

In the ______ Court of __________ County, ___________

)
_______________, West Palm Beach car accident Plaintiff )
) Case No. ______________
vs. )
)
_______________, Defendant )
MOTION FOR DIRECTED VERDICT BY WEST PALM BEACH CAR ACCIDENT PLAINTIFF
COMES NOW West Palm Beach car accident Plaintiff , by and through his attorneys of record, and, pursuant to Rule _____ of the ____________ Rules of Civil Procedure, moves the Court, at the close of all of the evidence to direct a verdict in West Palm Beach car accident Plaintiff ’s favor and against defendant on the issue of contributory negligence. As grounds for allowance of such motion, West Palm Beach car accident Plaintiff states that:
1. No evidence has been offered or received which raises a jury issue on the allegations of contributory negligence contained in defendant’s answer.
2. No evidence has been offered or received upon the trial tending to prove that West Palm Beach car accident Plaintiff was guilty of any contributory negligence.
3. The proximate cause of the occurrence in question was not any contributory negligence of West Palm Beach car accident Plaintiff .
4. Defendant was guilty of negligence which was the sole cause of West Palm Beach car accident Plaintiff ’s injury.
5. [Add any other grounds for the motion.]
WHEREFORE, for the reasons stated herein, West Palm Beach car accident Plaintiff moves the Court, pursuant to Rule ___, to direct a verdict in [his/her/its] favor and against defendant herein on the issue of contributory negligence.
______________________________
Attorneys for West Palm Beach car accident Plaintiff