STATE OF __________
COUNTY OF ___________ SUPERIOR COURT

ROBERT WILLIAMS, )
West Palm Beach Florida car accident injury Plaintiff , )
) C.A. No.
)
JOHN GREEN, )
Defendant. )

COMPLAINT

1. West Palm Beach Florida car accident injury Plaintiff , Robert Williams ("Williams"), is a resident of (insert city/town), County of (insert county), State of (insert state).

2. Defendant, John Green ("Green"), is a resident of (insert city/town), County of (insert county), State of (insert 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 (insert county and state or insert other applicable basis for venue).

COUNT I

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

5. On or about (insert date), at approximately (insert time), Williams was driving a motor vehicle owned by him (the "Williams Motor Vehicle").

6. At that time and place, Green was also operating a motor vehicle owned by him (the "Green Motor Vehicle") and Green operated the Green Motor Vehicle negligently so as to cause it to strike the Williams Motor Vehicle in a rear-end collision.

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

8. As a direct and proximate result of Green's breach of duty, and the resulting impact of the rear-end collision, Williams suffered and sustained severe injuries and damages, including rapid acute hyperextension reaction in the cervical spine causing a deceleration injury, with the impact propelling Williams' body forward. The impact stretched Williams' neck's musculature beyond normal physiological limits, leading to edema, hemorrhage, spasm, and pain. Williams has also sustained and suffered persistent symptoms documented by clinical objective findings and x-ray changes, including loss of lordotic curvature, permanent physical impairment and the loss of physical function to the cervical spine. His injuries sustained include subluxation, dislocation and fracture.

9. These injuries have caused Williams to incur substantial medical treatment, a loss of earning capacity, a loss of earnings and fringe benefits, pain, suffering and other incidental and consequential damages.

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

WEST PALM BEACH FLORIDA CAR ACCIDENT INJURY PLAINTIFF , WILLIAMS By his Attorneys

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WEST PALM BEACH FLORIDA CAR ACCIDENT INJURY PLAINTIFF , WILLIAMS, DEMANDS A TRIAL BY JURY ON ALL ISSUES TRIABLE AS OF RIGHT BY A JURY IN THE WITHIN ACTION.

WEST PALM BEACH FLORIDA CAR ACCIDENT INJURY PLAINTIFF , WILLIAMS By his Attorneys

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