Joe Doe, your supervising attorney, Course Project

IN THE DISTRICT COURT TEXARKANA ************************************************************************* BETTY BOOP Plaintiff v.

JOHN SMITH . Defendant ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: Before the Honorable Judge COMPLAINT WITH JURY DEMAND ENDORSED HEREON Mary Smith 123 Main St Texarkana, 45854 Telephone: (4 85)458 -5555 Atto rney for Plaintiff ************************************************************************* NOW COMES, Plaintiff, Betty Boop , by and through her counsel, Mary S mith , bringing suit against Defendant, John S mith ., and in support thereof states as follows: STATEMENT OF FACTS 1. Plaintiff, Betty Boop , is a resident of Texarkana . 2. Defendant John Smith is a resident of Texarkana. 3. On May 21, Bet ty Boop took $500 from the cash register at her place of work, with the intention of returning the money the next day. 4. Plaintiff states th at she was having difficulty coming up with money to buy the complete series of her favorite television show, MacGuyver, and was viewing the money as a loan. 5. Plaintiff states that Defendant saw Plaintiff take the money, and called the police. 6. Plaintiff states that she was arrested, but the charges were dropped when she returned the money. 7. Plaintiff states that when she arrived at work the next day, she overheard John Smith on the phone with his wife. During his conversation, J ohn stated that he caught another employee stealing, and she was arrested. FIRST CLAIM FOR RELIEF DEFAMATION 8. Plaintiff states that Defendant has defamed her character in making such a statement against Plaintiff. 9. Plaintiff states that she h as been damaged as a result of the statements made about her. 10. As a proximate result of the act ions of Defendant complained of herein, Plaint iff has suffered great mental and emotional stress, anxiety, humiliation and embarrassment . Plaintiff has also been forced to expend court costs and attorney’s fees. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for relief with judgment against Defendant for compensatory including lost past and future wages and benefits, punitive and general damages all in an amount exceeding the sum of Twenty -five Thousand Dollars ($2 5,000.00), plus interest from date of judgment at the sta tutory rate of interest, for her costs and reasonable attorney fees expended here and all other such legal and/or equitable relief as this Court may deem just and proper. Respectfully submitted, _____________________________________ Mary Smith JURY DEMAND Plaintiff demands a trial by a jury of her peers on all issues triable of right by jury. Respectfully submitted, _____________________________________ Mary Smith