STATE OF MAINE
_____ COUNTY SUPERIOR COURT
DOCKET NO. ____
[PLAINTIFF NAME],
Plaintiff,
v.
[DEFENDANT NAME],
Defendant.
COMPLAINT AND DEMAND FOR JURY TRIAL
[// GUIDANCE: Replace all bracketed text with client-specific information before filing.]
TABLE OF CONTENTS
- Document Header
- Defined Terms
- Parties
- Jurisdiction and Venue
- Factual Allegations
- Count I – Negligence
- Damages
- Prayer for Relief
- Jury Demand
- Reservation of Rights
- Verification & Signatures
1. DOCUMENT HEADER
1.1 Title. This Complaint asserts personal-injury claims arising under Maine tort law.
1.2 Date of Filing. [DATE]
1.3 Recitals. Plaintiff seeks monetary damages proximately caused by Defendant’s negligent acts and omissions occurring on or about [DATE OF ACCIDENT] in [LOCATION], Maine.
2. DEFINED TERMS
For clarity and consistency, the following terms, when capitalized, have the meanings set forth below:
“Award” – Any judgment, verdict, or settlement amount recovered in this action.
“Comparative Fault Statute” – Maine’s modified comparative negligence statute, 14 M.R.S. § 156.
“Incident” – The events of [DATE OF ACCIDENT] giving rise to Plaintiff’s injuries.
“Joint and Several Liability Rules” – Maine statutory and common-law rules governing joint, several, or apportioned liability among multiple tortfeasors.
“Non-Economic Damages” – Damages for pain, suffering, emotional distress, loss of enjoyment of life, and other intangible harms recognized under Maine law.
3. PARTIES
3.1 Plaintiff. [PLAINTIFF NAME] (“Plaintiff”) is an individual resident of [MUNICIPALITY], [COUNTY], Maine, and was so at all relevant times.
3.2 Defendant. [DEFENDANT NAME] (“Defendant”) is [an individual resident of / a corporation organized under the laws of] [STATE] with its principal place of business at [ADDRESS], and at all relevant times conducted activities within the State of Maine.
[// GUIDANCE: Add additional defendants or fictitious parties (e.g., ABC Corp.) as necessary.]
4. JURISDICTION AND VENUE
4.1 Subject-Matter Jurisdiction. This Court has jurisdiction under 4 M.R.S. § 105 and the Maine Rules of Civil Procedure because the amount in controversy exceeds the jurisdictional minimum and the claims arise under state tort law.
4.2 Personal Jurisdiction. Defendant is subject to personal jurisdiction in Maine because Defendant [resides in / is authorized to do business in / committed tortious acts within] Maine.
4.3 Venue. Venue is proper in _____ County pursuant to 14 M.R.S. § 501 because the Incident occurred in this county and/or Defendant resides or conducts business here.
5. FACTUAL ALLEGATIONS
5.1 On [DATE OF ACCIDENT] at approximately [TIME], Plaintiff was lawfully present at [LOCATION].
5.2 Defendant negligently [describe act or omission, e.g., “operated a motor vehicle while distracted”] in violation of Defendant’s duty to exercise reasonable care.
5.3 As a direct and proximate result of Defendant’s negligence, Plaintiff sustained severe bodily injuries, including but not limited to [LIST INJURIES], and incurred medical expenses, lost wages, and other damages.
5.4 Plaintiff’s conduct was at all times reasonable and in conformity with applicable laws and regulations.
6. COUNT I – NEGLIGENCE
6.1 Duty. Defendant owed Plaintiff a legal duty to exercise reasonable care under the circumstances.
6.2 Breach. Defendant breached that duty by [SPECIFY negligent conduct].
6.3 Causation. Defendant’s breach was the actual and proximate cause of Plaintiff’s injuries.
6.4 Damages. Plaintiff suffered damages as detailed below.
6.5 Comparative Fault. Plaintiff’s recovery is subject to Maine’s modified comparative negligence regime. Pursuant to the Comparative Fault Statute, Plaintiff’s fault, if any, does not bar recovery unless it equals or exceeds 50 percent of the total fault.
6.6 Joint and Several Liability. To the extent additional tortfeasors are found 50 percent or more at fault, Plaintiff pleads that such parties are jointly and severally liable under Maine law.
7. DAMAGES
7.1 Economic Damages. Past and future medical expenses, lost earnings, loss of earning capacity, and other out-of-pocket losses in an amount to be proven at trial.
7.2 Non-Economic Damages. Past and future pain and suffering, emotional distress, loss of enjoyment of life, and other intangible harms, in an amount to be determined by the jury, subject to any statutory limitations applicable under Maine law.
7.3 Punitive Damages. If discovery reveals express or implied malice or reckless indifference to the rights of others, Plaintiff reserves the right to seek punitive damages in accordance with Maine law and after obtaining leave of Court.
7.4 Pre- and Post-Judgment Interest. Plaintiff seeks interest as provided by 14 M.R.S. § 1602-B and applicable rules.
7.5 Costs and Attorney Fees. Plaintiff seeks allowable costs and such attorney fees as may be recoverable under contract, statute, or common law.
[// GUIDANCE: Maine generally does not impose a broad statutory cap on compensatory damages in ordinary personal-injury actions; confirm no special cap applies (e.g., governmental immunities) before finalizing.]
8. PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in favor of Plaintiff and against Defendant as follows:
a. Compensatory damages in an amount to be determined at trial;
b. Pre- and post-judgment interest as allowed by law;
c. Costs of suit and, where permitted, reasonable attorney fees;
d. Punitive damages as may be proven and authorized;
e. Such further legal or equitable relief as the Court deems just and proper.
9. JURY DEMAND
Pursuant to Me. R. Civ. P. 38 and Article I, Section 20 of the Maine Constitution, Plaintiff hereby demands a trial by jury on all issues so triable.
10. RESERVATION OF RIGHTS
Plaintiff reserves the right to amend this Complaint to add additional claims, parties, or prayers for relief as discovery and the interests of justice may warrant, including claims for equitable or injunctive relief consistent with the limited injunctive-relief scope authorized by metadata.
11. VERIFICATION & SIGNATURES
I, [PLAINTIFF NAME], verify that I have read the foregoing Complaint, that I am familiar with the facts stated therein, and that the facts are true and correct to the best of my knowledge, information, and belief.
[PLAINTIFF SIGNATURE]
[DATE]
Respectfully submitted,
[ATTORNEY NAME], Esq. (Bar #_____)
[LAW FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]
Counsel for Plaintiff
[// GUIDANCE: Maine requires attorney signature block with address, phone, and Maine Bar registration number. A separate certificate of service is customarily appended but is omitted here for brevity.]
CERTIFICATE OF SERVICE
I hereby certify that on [DATE] I served a true copy of this Complaint on counsel for Defendant, [DEFENSE COUNSEL NAME], by [MANNER OF SERVICE] pursuant to the Maine Rules of Civil Procedure.
[ATTORNEY NAME], Esq.
END OF TEMPLATE
[// GUIDANCE: Review court-specific formatting (margins, caption style, scheduling notice language) before filing. Confirm current filing fees, service requirements, and electronic-filing rules for the chosen county.]