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§ Form31 Complaint for Wrongful Death, Personal Injuries

Codes > Alabama Rules of Civil Procedure > Appendix I > Form31 Complaint

Form31. Complaint for Wrongful Death, Personal Injuries.

IN THE CIRCUIT COURT FOR__________ COUNTY, ALABAMA

    X., Administrator of                                                        )

    the Estate of A., and                                                      )

    Administrator of the                                                       )

    Estate of B., both                                                           )

    deceased; and C.,                                                         )                                                                 CIVIL ACTION NO.

                                                                                                                          ___________________________________

    individually                                                                     )

                                                                     Plaintiffs,       )

                                               vs.                                       )

    R.,                                                                                   )

                                                                      Defendant.    )

COMPLAINT

COUNT ONE

    1. [Identification of Parties]

    2. On the ______ day of ______, 19___, A., deceased, B., deceased, and plaintiff, C., were passengers in an automobile which was proceeding in a westerly direction along First Avenue, North, near its intersection with Second Street, in the City of Birmingham, Alabama.

    3. At the same time and place the defendant, R., was operating a truck and trailer in a westerly direction along First Avenue, North.

    4. The defendant, R., negligently [or wantonly] drove the truck and trailer into the automobile occupied by A., B. and C.

    5. As a result, A., suffered serious bodily injuries from which she died.

    Wherefore, plaintiff, X., as Administrator of the Estate of A., demands judgment against R., on the first count, in the sum of ______ Dollars and costs.

COUNT TWO

    1. Plaintiff, X, realleges paragraphs 1, 2, 3 and 4 of Count One.

    2. As a result, B., suffered serious bodily injuries from which she died.

    Wherefore, plaintiff, X., as Administrator of the Estate of B, demands judgment against the defendant, R., on Count Two, in the sum of ______ Dollars and costs.

COUNT THREE

    1. Plaintiff, C., realleges paragraphs 1, 2, 3 and 4 of Count One of this Complaint.

    2. As a result, plaintiff, C., was thrown out of the automobile in which he was riding and had his leg broken and was otherwise injured, was prevented from transacting his business, suffered great pain, both mentally and physically, and incurred expenses for medical attention and hospitalization, in the total sum of ______ Dollars.

    Wherefore, plaintiff, C., demands judgment against R., in the sum of ______ Dollars and costs.

_____________________________________,

Attorney for Plaintiffs.