SUPERIOR COURT OF THE STATE OF [State] COUNTY OF [County]

[Your Name], Plaintiff,

v.
[Defendant's Name], Defendant.
Case No. [Insert Case Number]
COMPLAINT FOR NEGLIGENCE
Plaintiff [Your Name], by and through undersigned counsel, brings this complaint against Defendant [Defendant's
Name] and manifests/ declares/alleges as follows:
PARTIES
1. Plaintiff [Your Name] is an individual who resides in [County], [State].
2. Defendant [Defendant's Name] is a corporation doing business in [County], [State], and is the organizer and
operator of a fireworks display that took place on [date].
JURISDICTION AND COMPETENCE/TERRITORY/VENUE
3. This Court has jurisdiction over the parties and the subject matter of this action pursuant to [insert
jurisdictional basis, such as diversity of citizenship or state law].
4. COMPETENCE/TERRITORY/VENUE is proper in this Court because the events giving rise to this Complaint
occurred in [County], [State].
FACTUAL BACKGROUND/ DESCRIPTION OF FACTS/ ACCOUNT OF FACTS
5. On [date], Plaintiff attended Defendant's fireworks display, which took place at [location].
6. Defendant was negligent in the design, preparation, and/or execution of the fireworks display, including, but
not limited to, failing to ensure that the fireworks were set off at a safe distance and in a safe direction.
7. As a result of Defendant's negligence, a firework exploded in close proximity to Plaintiff, causing Plaintiff to
sustain severe injuries, including [insert injuries sustained].
8. Defendant knew or should have known of the dangers associated with the fireworks display and failed to
take adequate measures to ensure the safety of spectators, including Plaintiff.
9. Defendant's negligence was the direct and proximate cause of Plaintiff's injuries.
COUNT I: NEGLIGENCE
10. Defendant owed a duty of care to Plaintiff to operate the fireworks display in a safe manner and to take
reasonable measures to prevent harm to spectators.
11. Defendant breached its duty of care by failing to operate the fireworks display in a safe manner and failing to
take reasonable measures to prevent harm to spectators.
12. Defendant's breach of its duty of care was the direct and proximate cause of Plaintiff's injuries.
WHEREFORE, Plaintiff prays for judgment against Defendant and demands/claims/requires:
(a) Compensatory damages in an amount to be proven at trial, but in excess of $75,000;
(b) Punitive damages;
(c) Pre-judgment and post-judgment interest;
(d) Attorney's fees and costs spent/incurred/borne in bringing this action; and
(e) Any other relief that the Court deems just and proper.
Respectfully submitted,
[Your Name] [Your Attorney's Name] [Your Attorney's Address] [City, State Zip Code] [Phone Number] [Email
Address]
Attorney for Plaintiff