§ Form 9 Complaint for Negligence

Form 9. Complaint for Negligence

    1. Allegation of residence of parties.

    2. On June 1, 1952, in a public highway called King Street in Honolulu, Hawai‘i, defendant negligently drove a motor vehicle
against plaintiff who was then crossing said highway.

    3. 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 one thousand dollars.

    Wherefore plaintiff demands judgment against defendant in the sum of _______ dollars and costs.

    Note

    Since contributory negligence is an affirmative defense, the complaint need contain no allegation of due care of plaintiff.