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DISTRICT COURT OF IDAHO
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[_] JUDICIAL DISTRICT, STATE OF IDAHO
COUNTY OF [__]
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[PLAINTIFF FULL NAME], )
an individual, )
) Case No. __
Plaintiff, )
)
v. ) COMPLAINT FOR DAMAGES
) (Motor-Vehicle Negligence)
[DEFENDANT FULL NAME], )
an individual, and )
DOES 1-10, inclusive, )
)
Defendants. )
__________ )

[// GUIDANCE: Insert additional party descriptors (e.g., corporate status, insurer, governmental entity) as applicable.]

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COMPLAINT
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TABLE OF CONTENTS
1. Parties .................................................................................... ¶1
2. Jurisdiction & Venue ....................................................................... ¶4
3. General Allegations ........................................................................ ¶7
4. Cause of Action: Negligence ................................................................. ¶12
5. Comparative Fault Allegations .............................................................. ¶18
6. Damages .................................................................................... ¶20
7. Prayer for Relief .......................................................................... ¶25
8. Demand for Jury Trial ...................................................................... ¶29
9. Certification & Signature .................................................................. ¶31

Plaintiff [PLAINTIFF FULL NAME] (“Plaintiff”), by and through undersigned counsel, brings this Complaint against Defendant [DEFENDANT FULL NAME] (“Defendant”) and alleges as follows:

1. PARTIES
   1.1 Plaintiff is, and at all relevant times was, a resident of [COUNTY], Idaho.
   1.2 Defendant is, and at all relevant times was, a resident of [COUNTY], Idaho.
   1.3 The true names and capacities of DOES 1–10 are presently unknown. Plaintiff will amend this Complaint to allege their true names and capacities when ascertained.
   [// GUIDANCE: Plead Doe defendants only if permitted by local rule and necessary to preserve claims.]

2. JURISDICTION & VENUE
   2.1 This Court has subject-matter jurisdiction over this civil action pursuant to Idaho Code § 1-705 and Idaho Rule of Civil Procedure 3(a), as the amount in controversy exceeds $10,000, exclusive of interest and costs.
   2.2 Personal jurisdiction is proper because Defendant resides in, and the collision occurred within, the State of Idaho.
   2.3 Venue lies in this County under Idaho Code § 5-404 because the cause of action arose here.

3. GENERAL ALLEGATIONS
   3.1 On or about [DATE] at approximately [TIME], Plaintiff was operating a [YEAR/MAKE/MODEL] traveling [DIRECTION] on [STREET/INTERSTATE], near [MILEPOST/INTERSECTION], in [CITY], Idaho.
   3.2 Defendant was operating a [YEAR/MAKE/MODEL] motor vehicle traveling [DIRECTION] on the same roadway.
   3.3 Defendant, while acting within the course and scope of [his/her] own affairs, failed to operate the vehicle with reasonable care, including but not limited to:
   a. Exceeding the posted speed limit;
   b. Failing to maintain a proper lookout;
   c. Failing to yield the right-of-way; and/or
   d. Operating the vehicle while distracted and/or fatigued.
   3.4 As a direct and proximate result of Defendant’s acts and omissions, Defendant’s vehicle collided with Plaintiff’s vehicle, causing Plaintiff to sustain severe bodily injuries and property damage.
   3.5 Plaintiff sought and continues to receive medical treatment, accruing medical expenses, lost wages, and other pecuniary losses.

4. CAUSE OF ACTION — NEGLIGENCE
   4.1 Plaintiff realleges and incorporates by reference ¶¶1-7 above.
   4.2 Defendant owed Plaintiff a duty to operate the motor vehicle with reasonable care and in compliance with Idaho’s motor-vehicle laws.
   4.3 Defendant breached that duty by engaging in the conduct described in ¶3.3.
   4.4 Defendant’s breach was the actual and proximate cause of Plaintiff’s injuries and damages.
   4.5 As a result, Plaintiff suffered special (economic) and general (noneconomic) damages in amounts to be proven at trial.

5. COMPARATIVE FAULT ALLEGATIONS
   5.1 Idaho is a comparative-fault jurisdiction. Idaho Code § 6-801 (2023) bars recovery only if Plaintiff’s negligence is equal to or greater than the combined negligence of all Defendants.
   5.2 Plaintiff denies any negligence; however, should comparative negligence be alleged, Plaintiff’s recoverable damages must be reduced only in proportion to any percentage of fault, if any, attributable to Plaintiff and only if that percentage is less than fifty percent (50%).

6. DAMAGES
   6.1 Economic Damages (Idaho Code § 6-1601): past and future medical expenses, lost earnings, diminished earning capacity, property damage, and out-of-pocket costs, all presently estimated to exceed $[______].
   6.2 Noneconomic Damages: pain, suffering, emotional distress, loss of enjoyment of life, inconvenience, disfigurement, and other general damages, subject to the statutory limitation set forth in Idaho Code § 6-1603 (2023), as annually adjusted by the Idaho State Insurance Fund.
   6.3 Pre-Judgment Interest: pursuant to Idaho Code § 28-22-104, from the date of loss.
   6.4 Costs & Attorney Fees: pursuant to Idaho R. Civ. P. 54(d) and Idaho Code §§ 12-120 & 12-121, as applicable.
   [// GUIDANCE: Consider pleading punitive damages only after complying with Idaho Code § 6-1604 and I.R.C.P. 9(b)-(c) procedures.]

7. PRAYER FOR RELIEF
   WHEREFORE, Plaintiff prays for judgment against Defendant as follows:
   A. For economic damages in an amount to be determined at trial;
   B. For noneconomic damages not to exceed the cap established under Idaho Code § 6-1603, as adjusted;
   C. For pre-judgment and post-judgment interest as allowed by law;
   D. For reasonable attorney fees and costs incurred herein;
   E. For such other and further relief as the Court deems just and proper.

8. DEMAND FOR JURY TRIAL
   Plaintiff hereby demands trial by jury on all issues so triable as a matter of right. Idaho Const. art. I, § 7; Idaho R. Civ. P. 38.
   [// GUIDANCE: To preserve jury demand, serve a separate written demand within 14 days after service of the last pleading directed to such issue if not included in the Complaint.]

9. CERTIFICATION & SIGNATURE
   Pursuant to Idaho Rule of Civil Procedure 11(a)(1), the undersigned certifies that the claims and allegations herein are well-grounded in fact and warranted by existing law or a good-faith argument for the extension, modification, or reversal of existing law, and that this pleading is not interposed for any improper purpose.

DATE: [____, 20__]

Respectfully submitted,

[ATTORNEY NAME], Esq. (ISB No. __)
[LAW FIRM NAME]
[Street Address]
[City, State ZIP]
Telephone: [__]
Facsimile: [_]
Email: [_]
Attorney for Plaintiff

VERIFICATION (OPTIONAL)
[// GUIDANCE: Idaho does not require verification, but one may be added to strengthen evidentiary value or comply with local practice.]

STATE OF IDAHO )
) ss.
COUNTY OF [_____] )

I, [PLAINTIFF FULL NAME], being first duly sworn, depose and say: I am the Plaintiff in the foregoing action; I have read the foregoing Complaint and know the contents thereof; the same is true to my own knowledge, except as to those matters stated on information and belief, and as to those matters I believe them to be true.

[PLAINTIFF FULL NAME]

SUBSCRIBED AND SWORN before me this ___ day of ____, 20__.

Notary Public for Idaho
Residing at: _____
My Commission Expires: _______

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END OF COMPLAINT
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