The above named Plaintiff(s), through [his or her or their] attorney, , as and for [his or her or their] complaint against the respective Defendant(s), allege(s) as follows:
1. That at all times pertinent hereto, the Plaintiff(s) was/were and continue to be residents of the County of and State of .
2. That at all times pertinent hereto, the Defendant, , was and continues to be a [(resident of the County of , State of )] [corporation authorized to do business within the State of and at all times pertinent herein maintained an office for the transaction of such business at [address], County of , State of ].
3. That heretofore and on or about [date], at or about [location], the Plaintiff, , was proceeding [location] of the aforesaid premises, [he or she] was caused to slip and fall and sustained serious physical injuries because of the dangerous and unlawful conditions of said area caused by the Defendant's negligence in design and/or maintenance as well as by an accumulation of .
4. That at the time of said accident, the Plaintiff, , was lawfully upon said premises [state reason].
5. That, upon information and belief, at all times herein mentioned, the Defendant, , reserved control over the area wherein the above described fall occurred.
6. That the Plaintiff did not contribute to the happening of the incident in any way.
7. That the aforesaid accident was the consequence wholly and solely of the negligence of the Defendant(s).
8. That the Plaintiff did not contribute to the happening of the incident in any way.
9. That by reason of the foregoing, the Plaintiff was caused to become sick, sore, lame and disabled, and was prevented from attending to [his or her] usual duties and occupation, and was compelled to secure medical care and attention, and may, in the future, be compelled to secure additional medical care and attention in an effort to heal [his or her] said injuries all to[his or her] damage in the sum of $[amount].
AS AND FOR A SECOND CAUSE OF ACTION ON BEHALF OF THE PLAINTIFFS AGAINST THE DEFENDANTS, IT IS ALLEGED:
10. That the Plaintiff repeats and realleges each and every allegation contained in paragraphs marked and numbered through as if fully set forth herein.
11. That prior to and at all times herein mentioned, the Plaintiff was and still continues to be the lawful [wife or husband] of the Plaintiff .
12. That by reason of the foregoing and by reason of the Defendant's negligence, Plaintiff has been deprived of the companionship and society of [his wife or her husband], the Plaintiff all to [his or her] damage in the sum of $[amount].
WHEREFORE, the Plaintiff demands judgment against the Defendant as follows:
a. $[amount] on the first cause of action.
b. $[amount] on the second cause of action.
c. Whatever relief the court deems just and appropriate.
DATED: [date of complaint]
[Name of Attorney for Plaintiff]
)