Complaint (Circuit Court For Fairfax County) (Page 2 of 3) in pdf

Complaint (Circuit Court For Fairfax County) Page 2

5. At the aforesaid time and location, Defendant, ____________, was operating her

vehicle travelling in the same direction as the Plaintiff.

6. At the aforesaid time and at the aforesaid location, Defendant, ___________,

suddenly rear-ended into Plaintiff’s vehicle.

7. Defendant had a duty to operate her vehicle with reasonable care and with due regard

for others using the road.

8. Notwithstanding these duties, defendant carelessly, recklessly and negligently

operated her automobile so that it collided with plaintiff’s automobile with great

force. Defendant was negligent by:

(a) Failing to pay full time and attention to her driving; failing to keep a proper

lookout;

(b) Failing to maintain proper control of her vehicle;

present;

(d) Failing to comply with the laws regarding operation of a motor vehicle in the

Commonwealth of Virginia.

9. As a direct and proximate result thereof, Plaintiff, _____________, sustained serious

injuries, has suffered and will continue to suffer great pain of body and mind; has

incurred hospital, doctor’s and related bills in an effort to be cured of said injuries.

WHEREFORE, Plaintiff, _______________, demands judgment against the defendant in

the sum of __________________________ ($____,000.00), and his costs expended in this

action, plus pre and post judgment interest.

Complaint (Circuit Court For Fairfax County) Page 2