2017 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

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