sample second amended complaint

sample second amended complaint - bodily injury and...

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IN THE CIRCUIT COURT FOR THE COUNTY OF LEON, FLORIDA PAUL PERKINS, PLAINTIFF ) CASE NO. 11-123 ) P l a i n t i f f , ) ) SECOND AMENDED COMPLAINT v . ) ) DAN DOOP, Defendant. ) ) COMES NOW Plaintiff, PAUL PERKINS, sues Defendant, DAN DOOP, and alleges a follows: 1. This is an action for damages that exceeds $15,000. 2. On or about June 1, 2011, Defendant owned and operated a motor vehicle on a public highway called Monroe Street in Tallahassee, Florida. 3. At that time and place, Defendant negligently operated or maintained the motor vehicle so that it collided with Plaintiff’s motor vehicle. 4. As a direct and proximate result of Defendant’s negligence, Plaintiff suffered
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Unformatted text preview: bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of ability to earn money and aggravation of a previously existing condition. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. Plaintiff’s automobile was damaged and he lost the use of it during the period required for its repair or replacement. WHEREFORE, Plaintiff demands a trial by jury and judgment for damages against Defendant. s/ Selwyn Belli SELWYN BELLI Attorney for Plaintiff 501 Lawyers Building T a l l a h a s s e e , F l o r i d a Tel: 385-0010 Fla. Bar No. 60606...
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This note was uploaded on 03/19/2012 for the course BUL 3310 taught by Professor Staff during the Spring '12 term at Florida State College.

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