Writing assignment legal writing

V I R G I N I A:

IN THE CIRCUIT COURT OF THE COUNTY OF HENRICO

AMY WHITE PLAINTIFF,

v. CASE NO. __________

BILLY VON

911 Please Help Lane

North Chesterfield, VA 23237

(PRIVATE SERVICE) DEFENDANT.

COMPLAINT

1. On or about March 1, 2019, Plaintiff was operating a motor vehicle in a westerly direction on River Road at its intersection with N. Parham Road in Henrico County, Virginia.

2. At that time and place, Defendant was operating a motor vehicle in a northerly direction on N. Parham Road at or near its intersection with River Road.

3. At that time and place, the intersection of N. Parham Road and River Road was controlled by a functioning traffic signal.

4. At that time and place, vehicles traveling West on River Road had the green light.

5. At that time and place, vehicles traveling North on N. Parham Road had the red light.

6. At that time and place, Plaintiff’s vehicle lawfully entered the intersection on a green light.

7. At that time and place, Defendant’s vehicle entered the intersection against a red light, crashed into Plaintiff’s vehicle, causing Plaintiff’s vehicle to collide with another vehicle in the intersection.

8. At that time and place, Defendant owed various duties of care including, but not limited to, the duty to obey all traffic signs and signals and the duty to yield the right of way to vehicles traveling West on River Road.

9. Defendant breached the duties of care owed Plaintiff.

10. The above-described crash was caused by carelessness, recklessness and negligence in the operation of the motor vehicle by Defendant.

11. As a proximate result of the above-described collision, Plaintiff was caused to suffer serious and permanent injuries; has suffered and will suffer in the future pain of body and mind; has incurred and will incur in the future medical and related expenses; and has been and will be in the future deprived of earnings and earning capacity.

WHEREFORE, Plaintiff demands judgment against Defendant in the sum of FOUR HUNDRED THOUSAND DOLLARS ($400,000.00), plus pre-judgment and post-judgment interest and costs.

Trial by jury is demanded.

AMY WHITE

By:____________________________

Good Attorney

VSB No. 10000

5000 Pay Day Road

Whatwasthisdudethinking, VA 23112

(804) XXX-XXX

(804) XXX-XXXX (facsimile)

Good [email protected]

Counsel for Plaintiff