Transcription of EXHIBIT 4:1 Sample Complaint (State)
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EXHIBIT 4:1 Sample Complaint (State). STATE OF COLUMBIA CAPITOL COUNTY CIRCUIT COURT. (caption) MARY E. JOHNSON, Plaintiff v. Civil Action, File No. 00000. ARTHUR HENDRICKS, Defendant JURY TRIAL DEMANDED. Complaint FOR NEGLIGENCE. The Plaintiff states that: (body) 1. The court has jurisdiction in this matter under Section 403A, Title 23 of the Columbia Revised Statutes. 2. Plaintiff is a paralegal and resides at 43 South Senate Avenue, Legalville, in Capitol County, Columbia. 3. Defendant is a baker and lives at 500 Maple Street, Legalville, in Capitol County, Columbia. 4. Defendant owns and operates the Deli Bakery at 508 Maple Street, Legalville, in Capitol County, Columbia. 5. On August 23, ____, at said bakery, Defendant sold Plaintiff a chocolate eclair, which was negligently prepared containing pieces of glass.
Personal injury Wrongful death Attorney malpractice Medical malpractice Infliction of emotional trauma Wrongful termination In any negligent tort, the following elements must be pled: The existence of a duty owed by the defendant to the plaintiff There is no hard and fast rule for determining the existence of a duty.
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