West Palm Beach Florida Automobile Accident Complaint – Common Carrier

Mary Jones
v. C.A. No. _______________
ABC Bus Lines, Inc.

COMPLAINT

1. Plaintiff, Mary Jones, resides at [address] in [city/town], County of [county]. State of [state].

2. Defendant, ABC Bus Lines, Inc. (“ABC”) is a corporation duly organized and existing under the laws of the State of [state].

3. The amount in controversy satisfies the jurisdictional requirements of this Court and venue is proper in this county [or insert other bases for jurisdictional and venue requirements].

4. On or about [date of accident], Plaintiff was a passenger on an ABC motor coach, a common carrier vehicle.

5. Plaintiff purchased at ticket from ABC in order to be a passenger on the ABC motor coach.

6. ABC, as a common carrier, owed to Plaintiff the highest duty of care.

7. ABC breached that duty of care when its employee, Martin Williams, drove the ABC motor coach in an improper and negligent manner, causing it to leave the road and strike a telephone pole.

8. As a result of ABC’s and Martin’s breach of their highest duty of care, Plaintiff suffered serious injury, as well as pain, suffering and emotional injury. Plaintiff has also sustained and will continue to incur medical expenses; Plaintiff has lost time from work and will continue to lose time from work as a result of the injury she has sustained.

WHEREFORE, Plaintiff demands judgment against ABC in an amount that exceeds the jurisdictional requirements of this Court plus interest and costs.

Plaintiff
By her attorneys,

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