Complaint (wreck Case - Negligence) (jury Trial) (version Ii)

• Library: Elements of Civil Causes of Action (SCBar) (2021 Ed.)

COMPLAINT (Wreck Case - Negligence) (Jury Trial) (Version II)

(Version II)

STATE OF SOUTH CAROLINA COUNTY OF __________

__________, Plaintiff(s),

vs.

__________, Defendant(s).

IN THE COURT OF COMMON PLEAS

Civil Action No. __________

COMPLAINT (Wreck Case - Negligence) (Jury Trial)

The Plaintiff(s), above-named, complaining of the Defendant(s) herein, would allege:

1. That the Plaintiff, __________, is a citizen and resident of the County of __________, State of South Carolina, and at the time of the occurrence herein mentioned was the driver of the 20___ automobile.

2. That the Plaintiff, __________, is a citizen and resident of the County of __________, State of South Carolina, and at the time of the occurrence herein mentioned was the driver of the 20___ automobile belonging to Plaintiff, __________.

3. That, upon information and belief, Defendant, is a citizen and resident of the County of __________, State of South Carolina, and at the time of the occurrence herein mentioned was the owner of a 20___ automobile.

4. That, upon information and belief, at all times mentioned herein, Defendant, __________, was acting as the agent and servant of Defendant...