IN THE CIRCUIT COURT IN AND FOR
ALACHUA COUNTY, FLORIDA
SAMPLE PLAINTIFF, :
SAMPLE DEFENDANT, :
COMPLAINT AND DEMAND FOR JURY TRIAL
COMES NOW, PLAINTIFF SAMPLE PLAINTIFF (“PLAINTIFF”) files this Complaint, respectfully showing the Court as follows:
This action alleges damages in excess of $15,000.00 exclusive of attorneys’ fees and costs.
The Defendant, is an insurance company providing uninsured motorist coverage which is applicable in this case.
On or about October 10, 2007, PLAINTIFF was injured in a motor vehicle accident although she was driving carefully; her injuries and damages from said accident exceed the insurance coverage of the person that caused the accident.
On said date, PLAINTIFF had uninsured motorist coverage with Sample Defendant.
As a result of said automobile collision, the PLAINTIFF has suffered a permanent injury within a reasonable degree of medical probability and/or scaring of disfigurement.
COUNT ONE – UNINSURED MOTORIST CLAIM AGAINST DEFENDANT
Paragraphs 1 through 5 of this Complaint are incorporated herein and by reference made a part hereof.
On the above referenced date, Sample Defendant provided uninsured and/or underinsured motorist coverage which covers said accident.
Wherefore, PLAINTIFF demands judgment against Sample Defendant, and relief in the form of: economic damages, including lost wages, benefits, and other remuneration, any other compensatory damages allowable under law; damages; emotional distress damages, general and special damages, prejudgment interest and post-judgment interest; costs, damages and any other relief the court deems just and proper.
DEMAND FOR JURY TRIAL
PLAINTIFF demands trial by jury on all issues so triable.
Date: July 6, 2009
Michael Massey, Esq.
Florida Bar No. 0153680
MASSEY & DUFFY, LLC
824 E. Univ. Ave.
Gainesville, FL 32601