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Auto Accident Complaint
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    (Name, Address Of Party or attorney)
    ____________
    ____________
    ____________
    State Bar No: ______
    (____) _____ - ________
    Attorney for _______ (Or "In Pro Per")

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ________

 

[PLAINTIFF(S) NAMES]
Plaintiffs,

 

v.

 

 
[DEFENDANT(S) NAMES]
Defendants
________________________________
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CASE NO: _______
 
COMPLAINT FOR
DAMAGES

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.


 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: _________________ ___________________________________

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