Structure of a Complaint

STATE OF ________________
COUNTY OF ______________
___________________COURT

CAPTION John Doe, ) Civil Action No.:____________

)
Plaintiff, )
v. )
)
Richard Roe, )
)
Defendant )
_______________________________ )
DESIGNATION (TITLE)
OF COMPLAINT COMPLAINT FOR NEGLIGENCE

Plaintiff alleges that:

ALLEGATION OF
1. The jurisdiction of this court is based on section ________, title ________ of
JURISDICTION the [State] Code.
2. Plaintiff is a plum ber, residing at 107 Main Street in the City of ___________
______________ County, State of ______________.
3. Upon inform ation and belief, defendant is a traveling salesm an, residing at
5747 Broadway Street in the City of Chicago, Cook County, Illinois.
4. On or about the second day of January, 1959 an autom obile driven by
defendant on Highway 18 in the vicinity of Verona, ___________, struck an
autom obile being driven by the plaintiff on said highway.
5. Defendant was negligent in the operation of said autom obile at the aforesaid
tim e and place as to:
a. Speed,
BODY
b. Lookout,
c. Managem ent and control.
6. As a result of said negligence of defendant his autom obile struck plaintiff’s
autom obile and caused the following dam age:
a. Plaintiff was subjected to great pain and suffering,
b. Plaintiff necessarily incurred m edical and hospital expense,
c. Plaintiff suffered a loss of incom e,
d. Plaintiff’s autom obile was dam aged.
PRAYER FOR W HEREFORE plaintiff dem ands judgm ent in the am ount of ten thousand
RELIEF dollars ($10,000), together with the costs and disbursem ents of this action

_________________________
SUBSCRIPTION Plaintiff
Address
State of _________________________
ss.
County of _______________________

John Doe, being first duly sworn on oath according to law, deposes and says
that he has read the foregoing com plaint by him subscribed and that the m atters
stated therein are true to the best of his knowledge, inform ation and belief.
VERIFICATION
_________________________
John Doe

Subscribed and sworn to before m e on this _______ day of ___________, 20____.

__________________________________
Notary Public
My com m ission expires: