[Firm Phone Number]
[Attorney Name and Bar Number]
Attorney for Plaintiff(s)
Arizona Superior Court, Yavapai County
(Tort – Motor Vehicle)
Plaintiff(s) allege as follows:
- At all times material hereto, Plaintiff, [Plaintiff Name], resided in [Plaintiff’s County of Residence].
- At all times mentioned herein, all Defendants were acting on behalf of themselves individually and on behalf, and to benefit, the marital community existing between them and for a family purpose. Further, the true and correct names of Defendants and their spouses fictitiously designated will be supplied by later amendment.
- All Defendants named herein were or may have been acting in the course and scope of employment, or agency, for or on behalf of each other, and/or for or on behalf of Defendants. Further the true and correct names of Defendants and their principals fictitiously designated will be supplied by later amendment.
- At all times herein, each Defendant was acting in concert, both as an agent and a principal, for and on behalf of all the other Defendants, so that the acts of one Defendant were the acts of all Defendants, thus making all the Defendants jointly and severally liable.
- On or about [Date of the Incident], Defendant negligently caused a car wreck to take place in Yavapai County, Arizona.
- [Defendant]’s violations of the statute(s), rule(s), and or regulation(s) constitute(s) negligence per se, which directly and proximately caused the accident and Plaintiffs’ damages complained of herein.
- As a direct and proximate result of [Defendant’s] negligence and/or negligence per se, Plaintiff suffered, and continue to suffer, damages including, but not limited to:
- Physical and emotional injuries, some of which may be permanent;
- Physical and emotional pain, discomfort, suffering, disability, disfigurement, and anxiety already experienced and to be experienced in the future;
- Loss of enjoyment of life and participation in life’s activities to the quality and extent normally enjoyed before the accident already experienced and to be experienced in the future; and
- General, special, incidental, consequential, consortium, compensatory and hedonic damages, the full nature and extent of which are not yet determined, including, but not limited to, medical expenses both past and future.
- As a direct and proximate result of the above, Plaintiffs are entitled to recover damages from Defendants in an amount to be determined at trial, which is in excess of the minimum jurisdictional limits of this Court.
Wherefore, Plaintiffs pray for judgment against Defendants, jointly and severally, as follows:
- For general, special, incidental, consequential, hedonic, consortium and compensatory damages, as alleged above, in amounts to be proven at trial;
- For costs incurred herein and accruing;
- For interest on the foregoing sums at the statutory rate; and
- For such other and further relief as the Court may deem just and proper.
Dated this ___ day of ____________, [year].
Attorney for Plaintiff(s)