Del. R. Civ. P. Super. Ct. Form 9

As amended through November 14, 2024
Form 9 - Complaint for Negligence

1. On June 1, 1936, in a public highway called Boylston Street in Boston, Massachusetts, defendant negligently drove a motor vehicle against plaintiff who was then crossing the highway.

2. Defendant was negligent in that:

(a) Defendant drove at an excessive speed.

(b) Defendant drove through a red light.

(c) Defendant had the last clear chance to avoid hitting plaintiff.

3. As a result plaintiff was thrown down and had his leg broken and was otherwise injured, was prevented from transacting his business as a lawyer in Wilmington, suffered great pain of body and mind, and incurred expenses for medical attention and hospitalization in the sum of one thousand dollars, itemized on Exhibit A.

Wherefore plaintiff demands judgment against defendant in the sum of ten thousand dollars and costs.

Del. R. Civ. P. Super. Ct. Form 9