Car Accident Complaint

 

IN THE CIRCUIT COURT IN AND FOR

ALACHUA COUNTY, FLORIDA

 

CASE NO: 

SAMPLE PLAINTIFF, :

:

Plaintiff, :

: :

:

SAMPLE DEFENDANT, :

:

Defendants. :

:

 

 

COMPLAINT AND DEMAND FOR JURY TRIAL

COMES NOW, PLAINTIFF SAMPLE PLAINTIFF (“PLAINTIFF”) files this Complaint, respectfully showing the Court as follows:

1.

                        This action alleges damages in excess of $15,000.00 exclusive of attorneys’ fees and costs.

2.

The Defendant, is an insurance company providing uninsured motorist coverage which is applicable in this case.

3.

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.

4.

 On said date, PLAINTIFF had uninsured motorist coverage with Sample Defendant.

5.

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

 

6.

Paragraphs 1 through 5 of this Complaint are incorporated herein and by reference made a part hereof.

7.

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

(352) 374-0877