§ 9-11-110. Form of complaint for negligence where plaintiff is unable to determine definitely whether the person responsible is C. D. or E. F. or whether both are responsible and where his evidence may justify a finding of wilfulness or of recklessness or of negligence

§ 9-11-110. Form of complaint for negligence where plaintiff is unable to determine definitely whether the person responsible is C. D. or E. F. or whether both are responsible and where his evidence may justify a finding of wilfulness or of recklessness or of negligence

 

IN THE _____ COURT OF _____ COUNTY

 

 

 

STATE OF GEORGIA

 

 

 

A.B.,

)

 

 

 

)

 

 

Plaintiff

)

 

 

 

)

 

 

 

)

 

 

v.

)

Civil action

 

 

)

File no. _____

 

C.D. and E.F.,

)

(Clerk will insert

 

Defendant

)

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