Daniel Cornell

Attorney Registration No. 0023222

Brown, Cornell & Michaels
3820 Justice Lane
Starville, Brockton 00021
555-555-5555 office
555-555-5556 fax
Attorney for Plaintiff

IN THE THIRD JUDICIAL DISTRICT COURT, WEST JORDAN DEPARTMENT IN

AND FOR SALT LAKE COUNTY, STATE OF UTAH
THOMAS COOK

COMPLAINT

Plaintiff,

(JURY DEMANDED)

v.
JEFFREY WASHINGTON
Defendant

Case no.___________________________
Judge_____________________________

Plaintiff Thomas Cook, by and through his counsel of record, hereby complains against
Defendant Jeffrey Washington as follows:
PARTIES
1. Thomas Cook (hereafter Plaintiff is a resident of Salt Lake County, State of Utah.
2. Jeffrey Washington (hereafter Defendant) is believed to be a resident of Davis
County, State of Utah.
JURISDICTION AND VENUE
3. The Third District Court in and for Salt Lake County, State of Utah, has jurisdiction
of the claims asserted below pursuant to the provision of 78A-5-102 (1) Utah Code
Ann/

4. Venue is properly in the Third Judicial Court in and for Salt Lake County, State of
Utah, pursuant to 78B-3-307(1)(a) Utah Code Ann., because the alleged incident
took place within Salt Lake County, State of Utah.
5. On Thursday, July 13, 2013, at approximately 9:00 PM, Plaintiff was driving north on
Derr Road towards his home in his Chevrolet Chevette.
6. Defendant was running errands and was also on his way home, traveling south on
Derr Road in his Jeep Grand Cherokee.
7. Plaintiffs vehicle, was struck head on by the Defendants vehicle.
8. Bobby Seale the closest person to witness the crash, told authorities that prior to the
crash, Defendant had been weaving in and out of his lane and swerved left of the
center lane into Plaintiffs lane.
9. The road condition was satisfactory and there were no abnormal weather conditions.
10. Defendant caused a head on collision with the Plaintiffs vehicle.
11. Defendant acknowledged that he had possibly been distracted with adjusting his
stereo controls.
12. As a result of the crash Plaintiff received broken nose, substantial facial lacerations
which required him to be rushed to the hospital.
13. Plaintiffs injuries as a result of the crash were severe and required many weeks of
recovery.
CLAIM FOR RELIEF AGAINST DEFENDANT
(NEGLIGENCE)
14. Plaintiff, by and through this reference, hereby incorporates paragraphs one through
thirteen above as if fully set forth herein.
15. Defendant owed Plaintiff a duty to operate his vehicle safely and prudently.
16. By conducting himself as described above, Defendant breached his duty to Plaintiff.
17. On July 13, 2013, Defendant negligently drove his vehicle and struck Plaintiff.
18. As the direct result of the Defendants negligence, plaintiff has suffered, continues to
suffer, and will suffer in the future, injuries, including pain of the face and mind and
has incurred and will continue to incur expenses for medical attention and treatment
and lost wages.
19. Defendants breach of duty to plaintiff was the direct cause of the Plaintiffs injuries.
JURY TRIAL DEMANDED

Plaintiff hereby requests that this matter be tried to a jury, and Plaintiff has submitted the
required jury fee herewith.

REQUEST FOR RELIEF

WHEREFORE, Plaintiff requests relief against Defendant as follows:
1. General damages for pain and suffering in an amount to be proven at trial.
2. Past and future medical expenses in an amount to be proven at trial.
3. Past and future economic loss in an amount to be proven at trial.
4. Permanent impairment and disability in an amount to be proven at trial.
5. Cost of suit and such further relief as the Court deems just and proper.
Dated this ____ day of October 2015.
BROWN, CORNWELL, & MICHAELS

/s
Daniel Cornwell
Attorney for Plaintiff

This document prepared and submitted by:

Daniel Cornell
Attorney Registration No. 0023222
Brown, Cornell & Michaels
3820 Justice Lane
Starville, Brockton 00021
555-555-5555 office
555-555-5556 fax
danielcornwell@gmail.com
Attorney for Plaintiff