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complaint drafting from my professional development class
Summer 2014
Kim Lohman
456 Forest Hills
Queens NY 11550
(718) xxx-xxxx
SUPERIOR COURT OF THE STATE OF NEWYORK COUNTY OF Kings Brooklyn
Kim Lohman
Plaintiffs,
v.
Wilber Hall Law school, Mr. John doe and Mrs. Jane doe, Secretary
Defendants
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CASE NO: 105-831
COMPLAINT FOR
NEGLIGENCE
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Plaintiff complains and for causes of action alleges as follows:
1. Plaintiff, Kim Lohman, is an individual and is
now, and at all times mentioned in this complaint is, a
resident of Brooklyn County, NewYork.
now, and at all times mentioned in this complaint is, a
resident of Brooklyn County, NewYork.
2. Defendant Wilbert Hall Law School is now, and at all times
mentioned in this complaint is, a Law school organized and
existing under the laws of the State of New York, with its
place of business in Nassau County,NewYork.
mentioned in this complaint is, a Law school organized and
existing under the laws of the State of New York, with its
place of business in Nassau County,NewYork.
3. Plaintiff does not know the true names of defendants
and therefore sues them by those fictitious names. And alleges, that each of
those defendants was in some manner negligently and proximately
responsible for the events and happenings alleged in this
complaint and for plaintiff's injuries and damages.
and therefore sues them by those fictitious names. And alleges, that each of
those defendants was in some manner negligently and proximately
responsible for the events and happenings alleged in this
complaint and for plaintiff's injuries and damages.
4. Tuesday, Lohman accompanied Tony Raiford to the second floor of Wilbert Hall Law School Annex.
5. Raiford had appointment with drafting instructor; Appointment was at 4:30.
6. At 5:00 Secretary left. Lohman, Raiford, and instructor were the only one on premises.
7. Lohman heard a crash on S.W. second ave.
8. A door was open to an office at the front of building.
9. Lohman went behind the desk to see what happened.
10. Lohman tripped on a cord, bumped into a desk as she fell.
11. Scissors that was on the edge of the desk fell onto the floor and Lohman landed on one of the blades. And discovered she could not move her right arm.
13. Lohman went to the hospital, her arm was broken, and there was a deep gash in her hand that required seven stitches.
Plaintiff, demands judgment against defendants,
and each of them, for the following:
and each of them, for the following:
14. Medical bills amounting $665.47.
15. Loss to perform tasks required as medical student.
16. Costs of this action; and
17. Any other and further relief that the court considers
proper.
proper.
DATED: _______________
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(Signature)
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VERIFICATION
I, ___, am a ___in the above-entitled action. I have read the foregoing ___and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein alleged on information and belief, and as to those matters, I believe it to be true.
I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed at Kings County, Brooklyn.
DATED: _________________ ___________________________________
Respectfully submitted,
Marilyn & Bridgett, LLC
___________________________
Marilyn & Bridgett
Kings Inner Harbor Center
400 East Pratt Street, 8th Floor
Brooklyn, New York 21201
(516)-xxx-xxx
you can read more articles of mine: www.marilynashley.blogspot.com
