LAW FIRM NAME}

{Address}
{City}, {State} {ZIP}
{Telephone:}
{Facsimile: }

{Lawyer Name (Bar No.)}

Email: {}

Attorney for Plaintiff

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF __________

[],

__ Gilardo Alcaraz ____ [NAME] Plaintiff,

v.

_ Landlords _____ [NAME] and DOES 1 through |

4, inclusive, Peter VECE et al.

Defendants.

Case No.: _______32.3_____________________

COMPLAINT FOR DAMAGES

 (Negligence)

Landlords left a broken meter box that injured the plaintiff

___________________________________________________________

Plaintiff alleges:

1. Plaintiff, ____ Alcaraz ______ [name], is an individual and is now, and at all times
mentioned in this complaint was, a resident of ______ San Mateo ____ County,
California.

2. Defendant landlords_____ [store] is now, and at all times mentioned in this complaint
was, a corporation organized and existing under the laws of the State of California, with
its place of business in _____ San Mateo _____ County, California.

3. Plaintiff does not know the true names of defendants DOES 1 through 3__, inclusive,
and therefore sues them by those fictitious names. __ Peter VECE,_ McGee, Berkeley
and O'Brien _______ [Optionally, in addition to language in charging allegations that
includes fictitiously named defendants: Plaintiff is informed and believes, and on the
basis of that information and belief alleges, that each of those defendants was in some
manner negligently and proximately responsible for the events and happenings alleged
in this complaint and for plaintiff's injuries and damages.]

4. Plaintiff is informed and believes, and on the basis of that information and belief
alleges, that at all times mentioned in this complaint, defendants were the agents and
employees of their codefendants, and in doing the things alleged in this complaint were
acting within the course and scope of that agency and employment.

5. At all times mentioned in this complaint, defendant ____landlords ______ [store] and
defendants DOES 1 through 50 owned and operated a _rental property_________
[grocery or as the case may be] store known as __Lincoln apartments________ [store
 name], located at ___ 247 Lincoln Avenue _______ [address], _Redwood_________
[city], ___ San Mateo ____ ___ County, California. Defendants invited the general
public, including plaintiff, to enter the premises of the _rental property_________
[grocery or as the case may be] store and live as tenants [food or as the case may be]
items from defendants.

6. On 4th June 1997 __________ [date], at approximately _____2p.m_____ [time],

__________ [describe incident, such as: plaintiff was on the premises of defendants'
grocery store for the purpose of goi9ng to his apartment. After entering the rental
property, plaintiff proceeded to the produce aisle when suddenly and without warning
plaintiff slipped on a broken water meter box and fell violently to the floor, causing
plaintiff to sustain the serious injuries and damages described below].

7. Defendants, as owners and operators of a __rental property________ [grocery or as

the case may be] store negligently:

a. Failed to maintain the water meter box_ [grocery or as the case may be] store
in a reasonably safe condition;

b. Allowed a slippery substance to come into contact with and remain on the floor
of the ____rental property______ [grocery or as the case may be] store when defendant
knew, or in the exercise of reasonable care should have known, that the substance
created an unreasonable risk of harm to tenants;

c. Failed to warn plaintiff of the danger presented by the presence of the slippery
substance on the floor;

d. Failed to install a repair the broken water meter box.

e. Failed to otherwise exercise due care with respect to the matters alleged in this
complaint.

8. As a direct and proximate result of the negligence of defendants as set forth above,
plaintiff slipped and fell while in the store.

9. As a further direct and proximate result of the negligence of defendants as set forth
above, plaintiff sustained the following serious injuries and damages: _physical
injuries_________ [set forth injuries and damages in detail, including medical expenses,
lost wages, pain and suffering, and physical injuries].
WHEREFORE, plaintiff demands judgment against defendants, and each of them, for
the following:

General damages according to proof;

__hurt his leg________ [Specify special damages, for example: Damages for medical
and related expenses according to proof;
Damages for loss of earnings according to proof;]
_____compensation for injury_____ [Specify any other relief sought;]
Interest according to law;
Costs of this action; and
Any other and further relief that the court considers proper.
Dated ___5th July 1998_______.

_________Douglas _____________________

[Signature]

Attorney for Plaintiff