Motor Vehicle Accident Complaint

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COMMONWEALTH OF VIRGINIA
PATRICK CIRCUIT COURT
****, Plaintiff
v.
HUNTER LEE SCARCE, Defendant
COMPLAINT
*. The Plaintiff, Dana Marie Snider, is a resident of Patrick County, Virginia.
*. The Defendant, Hunter Lee Scarce, was at all times relevant an employee of United Parcel Service (UPS).
*. On October *, *, the Defendant was operating a UPS truck in the course and scope of his employment.
*. On the date mentioned above, the Defendant was driving on Dangler Mountain Road in Patrick County, Virginia.
*. The Defendant negligently crossed over into the Plaintiff’s lane, causing a collision.
*. The Plaintiff sustained personal injuries and property damage as a result of the collision.
*. The Plaintiff’s damages exceed $*,*.
*. The Defendant’s actions constitute negligence, causing the Plaintiff to suffer harm.
WHEREFORE, the Plaintiff prays for judgment against the Defendant in an amount exceeding $*,*,plus costs, and any other relief the Court deems just and proper.
DATED: _____________
Respectfully submitted,
________________________________
Dana Marie Snider
[Plaintiff's Address]
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Dana, does this look good to you? Let me know if you need any changes or additional details!

Certainly, Dana. Here’s a more detailed version of your complaint:
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COMMONWEALTH OF VIRGINIA
IN THE CIRCUIT COURT OF PATRICK COUNTY
****, Plaintiff
v.
HUNTER LEE SCARCE, Defendant
COMPLAINT
*. The Plaintiff, Dana Marie Snider, is a resident of Patrick County, Virginia, and has been adversely affected by the actions of the Defendant.
*. The Defendant, Hunter Lee Scarce, was at all times relevant an employee of United Parcel Service (UPS), a company engaged in the business of parcel delivery.
*. On October *, *, the Defendant was operating a UPS truck in the course and scope of his employment for the purpose of delivering parcels.
*. On the aforementioned date, while driving on Dangler Mountain Road in Patrick County, Virginia, the Defendant negligently crossed over into the Plaintiff’s lane of travel without proper lookout and control.
*. The Defendant’s vehicle collided with the Plaintiff’s vehicle, causing substantial damage to the Plaintiff’s vehicle and resulting in personal injuries to the Plaintiff.
*. As a direct and proximate result of the Defendant's negligent actions, the Plaintiff sustained severe and permanent injuries, including but not limited to physical pain and suffering, mental anguish, and loss of enjoyment of life.
*. The Plaintiff has incurred and continues to incur medical expenses for the treatment of her injuries, and she will likely require future medical treatment.
*. The Plaintiff’s vehicle sustained significant property damage, necessitating substantial repair costs.
*. The Plaintiff’s damages exceed $*,*, exclusive of interest and costs.
*. The Defendant’s actions constitute negligence under Virginia law, causing the Plaintiff to suffer harm and damages.
WHEREFORE, the Plaintiff prays for judgment against the Defendant in an amount exceeding $*,*, plus interest, costs of this action, and any other relief the Court deems just and proper.
DATED: _____________
Respectfully submitted,
________________________________
Dana Marie Snider
[Plaintiff's Address]
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Does this version meet your needs, Dana? Let me know if you’d like to add or change anything.

Sure, Dana! Here's the complaint with a preliminary statement added:
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COMMONWEALTH OF VIRGINIA
IN THE CIRCUIT COURT OF PATRICK COUNTY
****, Plaintiff
v.
HUNTER LEE SCARCE, Defendant
COMPLAINT
Preliminary Statement:
The Plaintiff, Dana Marie Snider, brings this action against the Defendant, Hunter Lee Scarce, for damages arising from a motor vehicle accident caused by the Defendant's negligent operation of a UPS truck, resulting in personal injuries and property damage to the Plaintiff.
*. The Plaintiff, Dana Marie Snider, is a resident of Patrick County, Virginia, and has been adversely affected by the actions of the Defendant.
*. The Defendant, Hunter Lee Scarce, was at all times relevant an employee of United Parcel Service (UPS), a company engaged in the business of parcel delivery.
*. On October *, *, the Defendant was operating a UPS truck in the course and scope ofhis employment for the purpose of delivering parcels.
*. On the aforementioned date, while driving on Dangler Mountain Road in Patrick County, Virginia, the Defendant negligently crossed over into the Plaintiff’s lane of travel without proper lookout and control.
*. The Defendant’s vehicle collided with the Plaintiff’s vehicle, causing substantial damage to the Plaintiff’s vehicle and resulting in personal injuries to the Plaintiff.
*. As a direct and proximate result of the Defendant's negligent actions, the Plaintiff sustained severe and permanent injuries, including but not limited to physical pain and suffering, mental anguish, and loss of enjoyment of life.
*. The Plaintiff has incurred and continues to incur medical expenses for the treatment of her injuries, and she will likely require future medical treatment.
*. The Plaintiff’s vehicle sustained significant property damage, necessitating substantial repair costs.
*. The Plaintiff’s damages exceed $*,*, exclusive of interest and costs.
*. The Defendant’s actions constitute negligence under Virginia law, causing the Plaintiff to suffer harm and damages.
WHEREFORE, the Plaintiff prays for judgment against the Defendant in an amount exceeding $

Sure, Dana! Here's your complaint with the "COMES NOW..." statement added:
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COMMONWEALTH OF VIRGINIA
IN THE CIRCUIT COURT OF PATRICK COUNTY
****, Plaintiff
v.
HUNTER LEE SCARCE, Defendant
COMPLAINT
Preliminary Statement:
The Plaintiff, Dana Marie Snider, brings this action against the Defendant, Hunter Lee Scarce, for damages arising from a motor vehicle accident caused by the Defendant's negligent operation of a UPS truck, resulting in personal injuries and property damage to the Plaintiff.
COMES NOW the Plaintiff, Dana Marie Snider, and for her Complaint against the Defendant, Hunter Lee Scarce, alleges and states as follows:
*. The Plaintiff, Dana Marie Snider, is a resident of Patrick County, Virginia, and has been adversely affected by the actions of the Defendant.
*. The Defendant, Hunter Lee Scarce, was at all times relevant an employee of United Parcel Service (UPS), a company engaged in the business of parcel delivery.
*. On October *, *, theDefendant was operating a UPS truck in the course and scope of his employment for the purpose of delivering parcels.
*. On the aforementioned date, while driving on Dangler Mountain Road in Patrick County, Virginia, the Defendant negligently crossed over into the Plaintiff’s lane of travel without proper lookout and control.
*. The Defendant’s vehicle collided with the Plaintiff’s vehicle, causing substantial damage to the Plaintiff’s vehicle and resulting in personal injuries to the Plaintiff.
*. As a direct and proximate result of the Defendant's negligent actions, the Plaintiff sustained severe and permanent injuries, including but not limited to physical pain and suffering, mental anguish, and loss of enjoyment of life.
*. The Plaintiff has incurred and continues to incur medical expenses for the treatment of her injuries, and she will likely require future medical treatment.
*. The Plaintiff’s vehicle sustained significant property damage, necessitating substantial repair costs.
*. The Plaintiff’s damages exceed $*,*, exclusive of interest and costs.
*. The Defendant’s actions constitute negligence under Virginia law, causing the Plaintiff to suffer harm and damages.
WHEREFORE, the Plaintiff prays for judgment against the Defendant in an amount exceeding $*,*,