SUPERIOR COURT OF THE STATE
OF CALIFORNIA
COUNTY OF ________
- [PLAINTIFF(S) NAMES]
- Plaintiffs,
- v.
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- [DEFENDANT(S) NAMES]
- Defendants
- ________________________________
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- CASE NO: _______
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- COMPLAINT FOR
- DAMAGES
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Plaintiff complains and for causes of
action alleges as follows:
FIRST CAUSE OF ACTION
(For ________ Against ____)
<>. Defendant__, ___ is__, and
at all times herein mentioned was__, a resident__ of the City
of ___, County of __, State of California.
<>. Defendant__, ___, is__, and
at all times herein mentioned, was__ a Corporation organized
and existing under the laws of the State of California with principle
offices located at ___, in the City of ___, County of ___.
<>. Plaintiff__ is__ ignorant
of the true names and capacities of defendants sued herein as
DOES I through X, inclusive, and therefore sues__ these defendants
by such fictitious names. Plaintiff__ will amend this complaint
to allege their true names and capacities when ascertained.
<>. Plaintiff__ is__ informed
and believes__ and thereon alleges__ that, at all times herein
mentioned, each of the defendants sued herein was the agent and
employee of each of the remaining defendants and was at all times
acting within the purpose and scope of such agency and employment.
<>. At all times
herein mentioned, defendant ____ was the owner of a certain ____
automobile, California License No. _____.
<>. At all times
herein mentioned defendant ___ [--DOE NUMBER--] was the agent
and employee of ___ and in doing the things herein alleged, was
acting within the purpose and scope of this agency and employment.
<>. At all times
herein mentioned, defendant ____[--DOE NUMBER--] was driving
and operating the ___ automobile with the consent, permission,
and knowledge of defendant ____.
<>. At all times
herein mentioned plaintiff was, and is, the owner of a certain
___ automobile, California License no. ___.
<>. At all times
herein mentioned ___[--STREET--] and ___[--STREET--] were and
are intersecting public streets and highways in ___, California,
and running in a ___ and a ___ direction, respectively.
<>. On or about
___, 19__, at or about the hour of ___ _.M., plaintiff was operating
the ___ automobile along and on ___[--STREET--] in a general
___ direction at [--OR near--] the intersection of ___ and ___.
<>. At that time
and place defendants, and each of them, so negligently, carelessly,
recklessly, and unlawfully entrusted, managed, maintained, drove,
and operated the ___ automobile long and on ___[--STREET--] in
a general ___ direction, so as to proximately cause it to collide
with plaintiff's automobile and to proximately cause the injuries
and damages hereinafter described.
<>. As a proximate
result of the negligence, carelessness, and unlawfulness of defendants,
and each of them, and the resulting collision, as herein alleged,
plaintiff was injured in ___ health, strength, and activity,
sustaining injury to ___ body and shock and injury to ___ nervous
system and person, and among others, sustained the following
personal injuries: ____[--DESCRIBE--], all of which injuries
have caused and continue to cause plaintiff great mental, physical,
and nervous pain and suffering. These injuries will result in
some permanent disability to plaintiff, all to ___ general damage
in the sum of $________.
<>. As a further
proximate result of the negligence of defendants, and each of
them, as herein alleged, plaintiff was required to and did employ
physicians and surgeons for medical examination, treatment, and
care of these injuries and did incur medical and incidental expenses.
As a further proximate result of the negligence of defendants,
and each of them, plaintiff has incurred other and will incur
further medical and incidental expenses for the care and treatment
of these injuries, the exact amount of which is unknown at the
present time.
<>. At the time
of the events described herein plaintiff was gainfully employed
as ___, and was earning an average monthly income in excess of
$_____. As a further proximate result of the negligence of defendants,
and each of them, as herein alleged, plaintiff was prevented
from attending to his usual occupation and has been damaged thereby
the exact amount of which is unknown at the present time.
<>. Immediately
prior to and at the time of the collision, plaintiff's automobile
was in good mechanical condition. As a further proximate result
of the negligence of defendants, and each of them, as herein
alleged, plaintiff's automobile was damaged and depreciated to
the extent of $____, which sum is a reasonable amount for the
necessary repairs to the automobile.
<>. As a further
proximate result of the negligence of defendants, and each of
them, as herein alleged, plaintiff has lost use of his ___ automobile
for a period of ___ days, and was damaged thereby in the sum
of $____.
WHEREFORE, plaintiff
prays judgment against defendants, and each of them, as follows:
1. For general damages
in the sum of $_______.
2. For all medical and
incidental expenses according to proof.
3. For all loss of earnings
according to proof.
4. For repairs to plaintiff's
automobile in the sum of $______.
5. For loss of use of
that automobile in the sum of $______.
6. For costs of suit
herein incurred.
7. For such other and
further relief as the court may deem proper.
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DATED: ________________ |
_______________________ |
VERIFICATION
I, ___, am a ___in the above-entitled
action. I have read the foregoing ___and know the contents
thereof. The same is true of my own knowledge, except as to those
matters which are therein alleged on information and belief,
and as to those matters, I believe it to be true.
I declare under penalty of perjury that
the foregoing is true and correct and that this declaration was
executed at Long Beach, California.
DATED: _________________ ___________________________________
