§ Form 9 Complaint for negligence where plaintiff is unable to determine definitely whether the person responsible is A.B. or C.D. or whether both are responsible and where his evidence may justify a finding of wilfulness or of negligence

Form 9 Complaint for negligence where plaintiff is unable to determine definitely whether the person responsible is
A.B. or C.D. or whether both are responsible and where his evidence may justify a finding of wilfulness or of negligence

    1. On June 1, 1960, on a public highway called Capital Avenue in Frankfort, Kentucky, defendant A.B. or defendant C.D., or both defendants A.B. and C.D. wilfully or negligently drove a motor vehicle against plaintiff who was then crossing said highway.

    2. As a result plaintiff suffered bodily injuries, physical and mental pain, and his earning power was permanently impaired.

    3. In addition, plaintiff lost time from the transaction of his business and incurred hospital and medical expenses.

    Wherefore plaintiff demands judgment against A.B., against C.D., or against both, in the sum of ten thousand dollars and costs.

Research Note