Form of Complaint for Negligence When Plaintiff Is Unable to Determine Responsible Person

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IN THE __________ COURT OF __________ COUNTY STATE OF GEORGIA A.B., ) Plaintiff ) ) v. ) Civil action ) File no. __________ C.D. and E.F., ) (Clerk will insert Defendants ) number.) COMPLAINT The defendant C.D., herein named, is a resident of __________ (street), __________ (city), __________ County, Georgia, and is subject to the jurisdiction of this court. (Add appropriate statement about domicile of defendant E.F.) 1. On June 1, 1966, on a public highway called Broad Street in Athens, Georgia, defendant C.D. or defendant E.F., or both defendants C.D. and E.F., willfully or recklessly or negligently drove or caused to be driven a motor vehicle against plaintiff who was then crossing said highway. 2. As a result plaintiff was thrown down and had his leg broken and was otherwise injured, was prevented from transacting his business, suffered great pain of body and mind, and incurred expenses for medical attention and hospitalization in the sum of $1,000.00. Wherefore, plaintiff demands judgment against C.D. or against E.F. or against both in the sum of $10,000.00 and costs. __________________________________ Attorney for plaintiff __________________________________ Address

(Ga. L. 1966, p. 609, § 110; Ga. L. 1980, p. 649, § 8.)

RESEARCH REFERENCES

Am. Jur. 2d.

- 61A Am. Jur. 2d, Pleading, § 31 et seq.

C.J.S.

- 71 C.J.S., Pleading, § 43 et seq.


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