IN THE CIRCUIT COURT OF [COUNTY], MISSOURI

[PLAINTIFF NAME] )

[PLAINTIFF ADDRESS 1] )

[PLAINTIFF ADDRESS 2] ) Cause Number:

Plaintiff, )

)    Division Number:

  1. )

)

[DEFENDANT NAME] ) PLAINTIFF REQUESTS

[DEFENDANT ADDRESS 1] ) TRIAL BY JURY   

[DEFENDANT ADDRESS 2] )

Defendant. )

PETITION FOR DAMAGES

  1. Venue lies in this jurisdiction due to the fact that the cause of action arose in ~Contact._CountyMunicipality~, State of Missouri.
  2. That on or about ~Contact._DateofIncident0~, at approximately __________, Plaintiff ~Contact.FirstName~ ~Contact.LastName~ was operating a motor vehicle.
  3. That at the date and time in question, Plaintiff ~Contact.FirstName~ ~Contact.LastName~ was traveling in a generally [plaintiff’s direction of travel] direction over and upon [roadway 1].
  4. That [roadway 1] is a public thoroughfare that passes through, among other areas, ~Contact._CountyMunicipality~, State of Missouri.
  5. That at the date and time in question, Defendant ~Contact._AtFaultParty1~ was operating a motor vehicle.
  6. That at the date and time in question, Defendant ~Contact._AtFaultParty1~ was traveling in a generally [defendant’s direction of travel] direction over and upon [roadway 1].
  7. That at the date and time in question, the vehicle operated by Defendant ~Contact._AtFaultParty1~ came into contact with the rear of the vehicle operated by Plaintiff ~Contact.FirstName~ ~Contact.LastName~.  The force of the impact caused Plaintiff’s vehicle to then collide with the vehicle driven by __ [delete last sentence if third vehicle not involved].
  8. That Plaintiff ~Contact.FirstName~ ~Contact.LastName~ did not have the chance to avoid the collision due to its sudden and unforeseeable nature.
  9. That the incidents described in paragraphs 2-8 occurred with no negligence on the part of the Plaintiff, ~Contact.FirstName~ ~Contact.LastName~.
  10. That the injuries and damages alleged by Plaintiff ~Contact.FirstName~ ~Contact.LastName~ were directly and proximately caused by Defendant ~Contact._AtFaultParty1~ in one or more of the following respects:
    1. Defendant ~Contact._AtFaultParty1~ failed to exercise the highest degree of care to keep a careful lookout while operating his motor vehicle.
    2. Defendant ~Contact._AtFaultParty1~ failed to exercise the highest degree of care in permitting his vehicle to come into contact with the rear of Plaintiff’s vehicle.
    3. Such further negligent and careless acts and omissions as the evidence and discovery will reveal.
  11. That each and all of the aforesaid acts of Defendant ~Contact._AtFaultParty1~, both commission and omission were negligent and constituted negligence.
  12. That each and all of the aforesaid acts of Defendant ~Contact._AtFaultParty1~, both commission and omission, were a direct and proximate cause of the damages and injuries hereinafter described.
  13. That as a direct and proximate result of the aforesaid acts by Defendant ~Contact._AtFaultParty1~, both of omission and commission, Plaintiff ~Contact.FirstName~ ~Contact.LastName~ suffered serious, painful, and permanent injuries to Plaintiff’s ~Contact._InjuriesFromIncident~.
  14. That as a direct and proximate result of the aforesaid acts by Defendant ~Contact._AtFaultParty1~, both of omission and commission, Plaintiff ~Contact.FirstName~ ~Contact.LastName~ became sick, sore, lame and disordered.
  15. That as a direct and proximate result of the aforesaid acts by Defendant ~Contact._AtFaultParty1~, both of omission and commission, Plaintiff ~Contact.FirstName~ ~Contact.LastName~ has suffered, and will hereafter suffer physical pain and mental anguish.
  16. That as a direct and proximate result of these injuries, Plaintiff ~Contact.FirstName~ ~Contact.LastName~ has been obliged to seek medical treatment and has incurred significant medical expenses as a result.  
  17. That as a direct and proximate result of these injuries, Plaintiff ~Contact.FirstName~ ~Contact.LastName~ will in the future be obliged to seek additional medical treatment and will incur further medical expenses as a result.
  18. Plaintiff ~Contact.FirstName~ ~Contact.LastName~’s aforesaid injuries are permanent, serious and progressive in their nature.
  19. Plaintiff ~Contact.FirstName~ ~Contact.LastName~ will continue to suffer pain of body and mind for so long as plaintiff lives.
  20. Plaintiff ~Contact.FirstName~ ~Contact.LastName~ suffered lost wages in the amount of $______ [delete this sentence if not applicable].

WHEREFORE, plaintiff [PLAINTIFF NAME], prays judgment against the defendant [DEFENDANT NAME] in such sum over $25,000.00 as will reasonably and fairly compensate plaintiff [PLAINTIFF NAME] for loss and damage, for punitive damages in an amount necessary to deter and punish Defendant, together with costs herein expended, and such other and further relief as the Court deems just and proper.  

PLAINTIFF REQUESTS TRIAL BY JURY.  

 

Respectfully submitted,