§ Form 13 Complaint for Negligence Under the Federal Employers' Liability Act

Form 13. Complaint for Negligence Under the Federal Employers' Liability Act

(Caption--See Form 1.)

    1. (Statement of Jurisdiction--See Form 7.)

    2. At the times below, the defendant owned and operated in interstate commerce a railroad line that passed through a tunnel located at _______.

    3. On date, the plaintiff was working to repair and enlarge the tunnel to make it convenient and safe for use in interstate commerce.

    4. During this work, the defendant, as the employer, negligently put the plaintiff to work in a section of the tunnel that the defendant had left unprotected and unsupported.

    5. The defendant's negligence caused the plaintiff to be injured by a rock that fell from an unsupported portion of the tunnel.

    6. As a result, the plaintiff was physically injured, lost wages or income, suffered mental and physical pain, and incurred medical expenses of $_______.

    Therefore, the plaintiff demands judgment against the defendant for $_______, and costs.

(Date and sign--See Form 2.)