[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, )
) Case No. [CASE NUMBER]
v. )
)
[DEFENDANT NAME], )
Defendant. )

COMPLAINT FOR MEDICAL MALPRACTICE

1. Parties

1.1 Plaintiff [PLAINTIFF NAME] is a resident of [COUNTY], [STATE].
1.2 Defendant [DEFENDANT NAME] is a [physician/hospital/clinic] organized under the laws of [STATE], with a principal place of business at [ADDRESS].
1.3 At all relevant times, Defendant provided medical services to Plaintiff and owed Plaintiff a duty of care.

2. Jurisdiction and Venue

2.1 This Court has subject matter jurisdiction under [STATUTE].
2.2 Venue is proper in [COUNTY] because the acts and omissions occurred in this county and/or Defendant resides or does business here.

3. Factual Allegations

3.1 On [DATE], Plaintiff presented to [FACILITY] with [SYMPTOMS/CONDITION].
3.2 Defendant undertook to evaluate and treat Plaintiff.
3.3 Defendant failed to act in accordance with the applicable standard of care, including [FAILURES].
3.4 As a direct result, Plaintiff suffered [INJURY/COMPLICATIONS].

4. Standard of Care and Breach

4.1 The applicable standard of care required Defendant to [STANDARD OF CARE].
4.2 Defendant breached the standard of care by [SPECIFIC BREACHES].

5. Causation and Damages

5.1 Defendant's breaches were a substantial factor in causing Plaintiff's injuries.
5.2 Plaintiff has suffered and will continue to suffer damages including medical expenses, lost earnings, pain and suffering, and other losses.

6. Conditions Precedent

6.1 Plaintiff has complied with all required pre-suit notice and certificate of merit requirements, or such requirements are not applicable.

7. Cause of Action - Medical Negligence

7.1 Plaintiff realleges and incorporates the foregoing paragraphs.
7.2 Defendant owed Plaintiff a duty of care, breached that duty, and caused Plaintiff damages.

8. Damages

8.1 Plaintiff seeks compensatory damages in an amount to be proven at trial, including past and future medical expenses, lost wages, loss of earning capacity, and non-economic damages.
8.2 Plaintiff seeks all other damages and relief allowed by law.

9. Prayer for Relief

Plaintiff requests judgment against Defendant as follows:
a. Compensatory damages in an amount to be proven at trial.
b. Costs of suit and allowable interest.
c. Such other relief as the Court deems just.

10. Jury Demand

Plaintiff demands a trial by jury on all issues so triable.

11. Signature Block

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for Plaintiff

12. Verification (If Required)

text
I declare under penalty of perjury that the foregoing is true and correct.

______________________________
[PLAINTIFF NAME]
Date: [DATE]