IN THE CIRCUIT COURT OF [COUNTY] COUNTY, KENTUCKY

[PLAINTIFF NAME],
Plaintiff,

v. Civil Action No. _

[DEFENDANT NAME 1];
[DEFENDANT NAME 2]; and
[DEFENDANT NAME 3],
Defendants.

COMPLAINT FOR PERSONAL INJURY

[// GUIDANCE: Insert the clerk-assigned case number once issued. Add or delete Defendant lines as needed.]

TABLE OF CONTENTS
1. Parties
2. Jurisdiction & Venue
3. Factual Allegations
4. Causes of Action
4.1 Count I – Negligence
4.2 Count II – Negligence Per Se [OPTIONAL]
4.3 Count III – Loss of Consortium [OPTIONAL]
5. Damages
6. Demand for Jury Trial
7. Prayer for Relief
8. Reservation of Rights
9. Verification
10. Certificate of Service

1. PARTIES
   1.1 Plaintiff. [PLAINTIFF NAME] (“Plaintiff”) is an individual resident of [COUNTY] County, Kentucky, whose address is [ADDRESS].
   1.2 Defendant(s).
   a. [DEFENDANT NAME 1] (“Defendant 1”) is a [corporation/LLC/individual], organized under the laws of [STATE] with its principal place of business at [ADDRESS] and may be served via [registered agent/individual] at [SERVICE ADDRESS].
   b. [Add additional Defendants in similar format.]

[// GUIDANCE: If a Defendant is unknown, plead “UNKNOWN DEFENDANT(S)” pursuant to Ky. R. Civ. P. 9.06.]

2. JURISDICTION & VENUE
   2.1 Subject-Matter Jurisdiction. This Court has jurisdiction under Ky. Const. § 112(5) and KRS § 23A.010 because the amount in controversy exceeds the jurisdictional minimum of the Kentucky Circuit Courts.
   2.2 Personal Jurisdiction. Each Defendant is subject to personal jurisdiction because [it/he/she] resides in, is domiciled in, transacts business in, and/or caused tortious injury within the Commonwealth of Kentucky.
   2.3 Venue. Venue is proper in this Court under KRS § 452.450 because the causes of action arose in [COUNTY] County.

3. FACTUAL ALLEGATIONS
   3.1 On or about [DATE] (the “Incident Date”), Plaintiff was lawfully present at [LOCATION] (“Premises”).
   3.2 At approximately [TIME], Plaintiff was injured when [DETAILED DESCRIPTION OF INCIDENT].
   3.3 At all relevant times, Defendant(s) owed Plaintiff a duty to exercise ordinary care under Kentucky’s negligence standard.
   3.4 Defendant(s) breached that duty by, inter alia, [LIST SPECIFIC ACTS OR OMISSIONS].
   3.5 As a direct and proximate result of Defendant(s)’ breaches, Plaintiff sustained bodily injury, incurred medical expenses, lost wages, and suffered pain and suffering.

4. CAUSES OF ACTION
   4.1 COUNT I – Negligence
   a. Duty. Defendant(s) owed Plaintiff a duty of reasonable care under Kentucky common law.
   b. Breach. Defendant(s) breached that duty as described in Paragraph 3.4.
   c. Causation. Defendant(s)’ breach was the actual and proximate cause of Plaintiff’s injuries.
   d. Damages. Plaintiff suffered damages as set forth in Section 5.

[In accordance with Ky. Rev. Stat. Ann. § 411.182 (West 2023), Plaintiff affirmatively pleads apportionment of fault among all parties, including unknown or non-party tortfeasors.]

4.2 COUNT II – Negligence Per Se [OPTIONAL]
a. Defendant(s) violated [STATUTE/REGULATION], enacted for the safety of the class of persons including Plaintiff.
b. The statutory violation constitutes negligence per se, entitling Plaintiff to damages.

4.3 COUNT III – Loss of Consortium [OPTIONAL]
a. [CONSORTIUM PLAINTIFF NAME], spouse of Plaintiff, realleges the foregoing paragraphs.
b. As a result of Plaintiff’s injuries, [he/she] has suffered loss of services, society, and consortium.

5. DAMAGES
   5.1 Economic Damages. Past and future medical expenses, lost wages, diminished earning capacity, and property damage.
   5.2 Non-Economic Damages. Past and future pain and suffering, mental anguish, impairment of the enjoyment of life.
   5.3 Punitive Damages. Pursuant to KRS § 411.184, Plaintiff seeks punitive damages due to Defendants’ gross negligence or reckless disregard for safety.
   5.4 Damage Caps. Kentucky presently imposes no statutory cap on compensatory or punitive damages for personal injury actions. [// GUIDANCE: Confirm status at filing; update if statutory changes occur.]

6. DEMAND FOR JURY TRIAL
   Plaintiff demands a trial by jury on all issues so triable as a matter of right.

7. PRAYER FOR RELIEF
   WHEREFORE, Plaintiff respectfully requests that the Court enter judgment:
   a. Awarding compensatory damages in an amount to be determined by the jury;
   b. Awarding punitive damages as allowed by law;
   c. Awarding pre- and post-judgment interest;
   d. Awarding costs herein, including reasonable attorney’s fees where permitted; and
   e. Granting all such other and further relief as the Court deems just and proper.

8. RESERVATION OF RIGHTS
   Plaintiff reserves the right to amend this Complaint to conform to the evidence, add additional parties or claims, and seek any further relief allowed by law.

9. VERIFICATION
   I, [PLAINTIFF NAME], verify under penalty of perjury that I have read the foregoing Complaint and that the factual statements contained herein are true and correct to the best of my knowledge, information, and belief.

[PLAINTIFF NAME]
Date: __

[// GUIDANCE: Kentucky practice allows either verification or non-verified pleadings. Adapt to local judge preference.]

10. CERTIFICATE OF SERVICE
    I hereby certify that on this __ day of ____, 20__, I served a true and correct copy of the foregoing Complaint upon:

[DEFENSE COUNSEL NAME & ADDRESS]

by [U.S. Mail/hand-delivery/e-filing system].

[PLAINTIFF’S COUNSEL NAME]
[KBA No. _]
[FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]

GENERAL DRAFTER’S NOTES
[// GUIDANCE:
1. Apportionment. Under KRS § 411.182, the jury must allocate fault among all parties and non-parties; Kentucky does not follow joint & several liability. Plead unknown tortfeasors if necessary.
2. Statute of Limitations. Personal injury actions in Kentucky must be filed within one (1) year of the date of injury (KRS § 413.140). Confirm timeliness.
3. Comparative Fault. Kentucky applies “pure” comparative fault; damages are reduced, not barred, by Plaintiff’s negligence.
4. Punitive Damages. Include specific facts indicating oppression, fraud, or malice to sustain a punitive claim.
5. Medical Lien Notices. If medical expenses are claimed, ensure compliance with KRS § 411.203 et seq. regarding provider liens.
6. Electronic Filing. Check local rules for mandatory e-filing and signature requirements.
]