2010 Georgia Code
TITLE 9 - CIVIL PRACTICE
CHAPTER 11 - CIVIL PRACTICE ACT
ARTICLE 10 - FORMS
§ 9-11-114 - Form of complaint for negligence under Federal Employers' Liability Act
O.C.G.A.
9-11-114 (2010)
9-11-114. Form of complaint for negligence under Federal Employers' Liability Act
IN THE COURT OF COUNTY
STATE OF GEORGIA
A.B., )
Plaintiff )
)
v. ) Civil action
) File no.
C.D., ) (Clerk will insert
Defendant ) number.)
COMPLAINT
The defendant C.D., herein named, is a resident of (street),
(city), County, Georgia, and is subject to the jurisdiction of this
court.
1.
During all the times herein mentioned defendant owned and operated in
interstate commerce a railroad which passed through a tunnel located at
and known as Tunnel No. .
2.
On or about June 1, 1966, defendant was repairing and enlarging the tunnel
in order to protect interstate trains and passengers and freight from injury
and in order to make the tunnel more conveniently usable for interstate
commerce.
3.
In the course of thus repairing and enlarging the tunnel on said day,
defendant employed plaintiff as one of its workmen and negligently put
plaintiff to work in a portion of the tunnel which defendant had left
unprotected and unsupported.
4.
By reason of defendant's negligence in thus putting plaintiff to work in
that portion of the tunnel, plaintiff was, while so working pursuant to the
defendant's orders, struck and crushed by a rock which fell from the
unsupported portion of the tunnel and was (here describe plaintiff's injuries).
5.
Prior to these injuries, plaintiff was a strong, able-bodied man, capable
of earning $ per day. By these injuries he has been made incapable of
any gainful activity, has suffered great physical and mental pain, and has
incurred expense in the amount of $ for medicine, medical attendance, and
hospitalization.
Wherefore, plaintiff demands judgment against defendant in the sum of $
and costs.
Attorney for plaintiff
Address
Graham Syfert - Jacksonville Lawyer 
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