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IN THE CIRCUIT COURT OF PLAINTIFFS COUNTY, ALABAMA John and Patty Smith PLAINTIFFS, Vs. Case No.

CV-_________ Careless Trucking L.L.C and Jim Joe as an Individual and agent of Careless Trucking AND FICTIOUS PARTIES A-Z, corporations And individuals whose true names are otherwise Unknown to the Plaintiffs and whose true names, when ascertained will be substituted be amendment, being that person(s), firm(s), corporation(s), partnership or other legal entity who were responsible for the Tractor Trailer at the time and date of these specific incidents which made the basis of this suit. DEFENDANTS, Complaint Count one NEGLIGENCE AND WANTONESS (CLAIM OF MAMIE PERKINS)

1.

The plaintiffs John Smith and Patty smith are residents of Alabama

and are over nineteen years of age. 2. The defendant Careless Trucking was doing business In Alabama

on the date and time of the incident giving rise to this complaint. 3. On to, wit: August 6th 2005 Jim Joe was operating a tractor trailer

in Plaintiffs County Alabama , while acting in the Line and Scope of his employment, on Highway 80 west at the Intersection of Plaintiffs County road 21.

4.

On the same date, at the same time and place Jim Joe was

operating an automobile on the public roadway and Jim Joe negligently and wantonly caused or allowed the Tractor Trailer he was operating for Careless Trucking to collide with the vehicle occupied by Patty Smith and being driven By John Smith . 5. As a proximate consequence of the of the Defendants said

negligence and wantonness, the vehicle operated by the defendant struck the vehicle occupied by the Plaintiffs and the Plaintiff was caused to suffer injury to neck, Back and shoulder; She received bruises, strains and contusions; she was otherwise physically injured and has suffered great pain and mental and emotional distress. Plaintiff Patty Smith has also incurred substantial medical and hospital bills For treatment of the physical injuries she received in the said accident. WHEREFORE, plaintiff demands judgment against the defendant Under Count one of the complaint for actual, compensatory and punitive damages in such an amount as a jury may award. (exceeding the jurisdictional minimum of this court but not exceeding $74,999.00)

COUNT II NEGLEGENCE AND WANTONESS (Claim of John Smith) 6. Plaintiff, John Smith hereby adopts and Incorporates

paragraphs 0ne through five as if set out here in full.

7.

As a proximate consequence of the of the Defendants said

negligence and wantonness, the vehicle operated by the defendant struck the vehicle occupied by the Plaintiffs and the Plaintiff, John Smith was caused to suffer injury to neck, Back and shoulder; he received bruises, strains and contusions; he was otherwise physically injured and has suffered great pain and mental and emotional distress. Plaintiff, John Smith has also incurred expense due to the damage caused to his vehicle during the collision. WHEREFORE, plaintiff demands judgment against the defendant Under Count one of the complaint for actual, compensatory and punitive damages in such an amount as a jury may award. (Exceeding the jurisdictional minimum of this court but not exceeding $74,999.00) Respectfully submitted on this the _____day of _____ 2006

___________________ Joe Judgment Attorney for the Plaintiffs Of Counsel: Joe Judgment 100 Thousand dollar Lane SueumHard Al

PLAINTIFFS DEMAND A TRIAL BY A STRUCK JURY

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