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Torts

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Submitted By aliciaj78
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Jackson, Doe & Nevels
John G. Doe, ESQ., SBN. 000000X
1000 Any Street, Suite 55
Any Town, Fredonia 50000
Phone: (333) 345-6789
Fax: (888) 345-9876

Attorney for Plaintiff
DEIRDRE JONES

SUPERIOR COURT FOR THE STATE OF FREDONIA

DEIRDRE JONES, an individual, ) Case No. Plaintiff, ) ) (Unlimited Civil Case) )
v. ) COMPLAINT FOR DAMAGES: )
JACK DANIELS, an individual ) CAUSE OF ACTION ) Defendant. )

GENERAL ALLEGATIONS

1. At all times mentioned herein, Plaintiff DEIRDRE JONES (hereinafter the “JONES and/or “Plaintiff”) was, and now is, and individual and a resident of the state of Fredonia.
2. At all times mentioned herein, Defendant JACK DANIELS (hereinafter “MUGGER”), was, and now is an individual and a resident of the State of Fredonia, and within the jurisdiction of this Court.
3. The true names or capacities, whether individual; corporate, associate, or otherwise, of the Defendants are unknown to Plaintiff at this time, which therefore sues such Defendant by such fictitious names, and will amend this Complaint to allege their names and capacities when ascertained. Plaintiff is informed and believes, and thereon alleges, that each of said factiously named Defendants is responsible for the occurrences herein alleged, and that Plaintiff’s injuries, as herein alleged, where proximately caused by said Defendant.
4. Plaintiff is informed and believes and thereon alleges that at all times herein mentioned each of the Defendants sued herein as DOE were the agents, servants, employees or employers and with the permission and consent of their Co-Defendants.
FIRST CAUSE OF ACTION
(FOR ASSAULT)
(AGAINST DEFENDANT JACK DANIELS)
5. Plaintiff refers to the whole of the General Allegations, and by reference incorporates the same herein as if set forth in full here at.

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