Injuries Caused By Negligence On A Railroad - Legal Draft

A.B.,

the above-named plaintiff states as follows:-On

the .........day of ............19.................., the defendants were

common carriers of passengers by railway between ..........and..............On

that day the plaintiff was a passenger in one of the carriages of the

defendants on the said railway.While

he was such passenger, at .............[or near the station of

.......................or between the stations of

.........and.................... ] a collision occurred on the said railway

caused by the negligence and un skill fullness of the defendants servants

whereby the plaintiff was much injured [having his leg broken, his head cut,

etc., and state the special damage, if any, as] and incurred expense for

medical attendance and is permanently disabled from carrying on his former

business as (a salesman).[As

in paras.4 and 5 of Form No.1, and Relief claimed.][Or

thus:-- 2.On that day the defendants by their servants so negligently and

unskillfully drove and managed an engine and a train of carriages attached

thereto upon and along the defendants' railway which the plaintiff was then

lawfully crossing, that the said engine and train were driven and struck

against the plaintiff, whereby, etc., as in para.3]