Syfert Injury Law Firm
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Call Now: 904-383-7448IN 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
(Ga. L. 1966, p. 609, § 114; Ga. L. 1980, p. 649, § 12.)
Cited in White v. Augusta Motel Hotel Inv. Co., 119 Ga. App. 351, 167 S.E.2d 161 (1969); Dillingham v. Doctors Clinic, 135 Ga. App. 736, 219 S.E.2d 2 (1975).
- What employees are engaged in interstate commerce within the Federal Employers' Liability Act, 10 A.L.R. 1184; 14 A.L.R. 732; 24 A.L.R. 634; 29 A.L.R. 1207; 49 A.L.R. 1339; 65 A.L.R. 613; 77 A.L.R. 1374; 90 A.L.R. 846.
Applicability of state statutes and rules of law to actions under Federal Employers' Liability Act, 36 A.L.R. 917; 89 A.L.R. 693.
Railroad employee injured while engaged in removing weeds, brush, etc., from roadbed or right of way, as within Federal Employers' Liability Act, 143 A.L.R. 481.
Right of foreign domiciliary, or of ancillary, personal representative to maintain action for death under Federal Employers' Liability Act, 163 A.L.R. 1284.
Applicability of state practice and procedure in Federal Employers' Liability Act actions brought in state courts, 79 A.L.R.2d 553.
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This Georgia Code resource is curated by this site's author, a personal injury and workers' compensation attorney admitted in Georgia (State Bar of Georgia No. 881027, since 2006) and Florida. Attorney Syfert regularly works with Title 9 in the context of Georgia civil practice and statute of limitations and represents clients throughout Northeast Florida and South Georgia. For legal consultation, call 904-383-7448.