[// GUIDANCE: This template is drafted for use in the Supreme Court of the State of New York.
Adapt all bracketed placeholders before filing. Ensure the facts pled are accurate and that any statutory citations remain current.]

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF [COUNTY]
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[PLAINTIFF FULL LEGAL NAME], Index No.: _____

Plaintiff, VERIFIED COMPLAINT
- against - Jury Trial Demanded

[DEFENDANT FULL LEGAL NAME(S)],

Defendant(s).
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Plaintiff, by [his/her/their] attorneys, [LAW FIRM NAME], complaining of the Defendant(s), alleges upon knowledge as to Plaintiff and Plaintiff’s own acts, and upon information and belief as to all other matters, as follows:

TABLE OF CONTENTS

1. Parties
2. Jurisdiction & Venue
3. Relevant Statutory Framework
4. General Allegations (Accident Facts)
5. Causes of Action
   5.1 Negligence
   5.2 Negligence Per Se (Optional)
   5.3 Statutory Owner Liability (VTL § 388) (Optional)
   5.4 Respondeat Superior (Optional)
6. Damages
7. Jury Demand
8. Prayer for Relief
9. Verification

1. PARTIES

1. At all relevant times, Plaintiff [PLAINTIFF NAME] (“Plaintiff”) was and is a resident of the County of [COUNTY], State of New York.
2. Upon information and belief, Defendant [DEFENDANT DRIVER NAME] (“Driver-Defendant”) was and is a resident of the County of [COUNTY], State of [STATE].
3. Upon information and belief, Defendant [VEHICLE OWNER NAME] (“Owner-Defendant”) [is a resident of / is a business entity organized under the laws of] the State of [STATE] with its principal place of business at [ADDRESS].
4. [Optional: Insert additional party allegations—employer, municipality, manufacturer, etc.]

2. JURISDICTION & VENUE

5. Jurisdiction is proper under N.Y. C.P.L.R. § 301 because Defendant(s) reside in, transact business in, or otherwise have sufficient contacts with the State of New York.
6. Venue is proper in this County pursuant to N.Y. C.P.L.R. § 503 because [one or more parties reside in this County / the accident occurred in this County].
7. The amount in controversy exceeds the monetary jurisdiction of all lower courts that would otherwise have jurisdiction.

3. RELEVANT STATUTORY FRAMEWORK

8. This action arises from a motor-vehicle accident subject to New York’s “No-Fault” regime (N.Y. Ins. Law §§ 5101–5108) and New York common-law tort principles.
9. Plaintiff suffered a “serious injury” within the meaning of N.Y. Ins. Law § 5102(d), including but not limited to [place applicable statutory categories here, e.g., “significant limitation of use of a body function or system,” “fracture,” “permanent consequential limitation,” or “90/180 category”].
10. Plaintiff has incurred and/or will incur “basic economic loss” in excess of $50,000 as defined by N.Y. Ins. Law § 5102(a) and is therefore entitled to maintain this tort action for additional economic and non-economic damages.
11. Comparative fault, if any, is governed by N.Y. C.P.L.R. Art. 14-A (pure comparative negligence).

4. GENERAL ALLEGATIONS (ACCIDENT FACTS)

12. On [DATE] at approximately [TIME], Plaintiff was operating/occupying a [YEAR, MAKE, MODEL, PLATE NO.] (“Plaintiff’s Vehicle”) traveling [DIRECTION] on [ROADWAY] near [INTERSECTION / MILE MARKER] in [CITY/TOWN], County of [COUNTY], State of New York.
13. At the same time and place, Driver-Defendant was operating a [YEAR, MAKE, MODEL, PLATE NO.] (“Defendant’s Vehicle”), owned by Owner-Defendant.
14. Defendant(s) operated, maintained, and controlled Defendant’s Vehicle negligently, carelessly, and recklessly, including but not limited to:
    a. Failing to keep a proper lookout;
    b. Traveling at an unlawful and/or unsafe speed;
    c. Failing to yield the right-of-way;
    d. Violating N.Y. Veh. & Traf. Law (“VTL”) §§ [INSERT], among other statutory violations.
15. As a direct and proximate result of Defendant(s)’ negligence, Defendant’s Vehicle [collided with / struck / rear-ended] Plaintiff’s Vehicle, causing Plaintiff to sustain the injuries set forth herein.
16. Plaintiff was at all times exercising due care for [his/her/their] own safety.

5. CAUSES OF ACTION

5.1 FIRST CAUSE OF ACTION – NEGLIGENCE (Against Driver-Defendant)

17. Plaintiff repeats and realleges ¶¶ 1–16 as though fully set forth herein.
18. Driver-Defendant owed Plaintiff a duty to operate Defendant’s Vehicle in a reasonably safe manner in compliance with applicable statutes, regulations, and the common law.
19. Driver-Defendant breached said duty in the manner described above.
20. Driver-Defendant’s negligence was a direct and proximate cause of the collision and Plaintiff’s resulting injuries and damages.

5.2 SECOND CAUSE OF ACTION – NEGLIGENCE PER SE (Optional)

21. Plaintiff repeats and realleges ¶¶ 1–20.
22. Driver-Defendant violated VTL §§ [INSERT SPECIFIC SECTIONS], enacted for the safety of motorists and pedestrians.
23. Such statutory violations constitute negligence per se, directly and proximately causing Plaintiff’s injuries.

5.3 THIRD CAUSE OF ACTION – STATUTORY OWNER LIABILITY (VTL § 388) (Against Owner-Defendant) (Optional)

24. Plaintiff repeats and realleges ¶¶ 1–23.
25. At all relevant times, Owner-Defendant was the owner of Defendant’s Vehicle within the meaning of VTL § 388(1).
26. Pursuant to VTL § 388, Owner-Defendant is vicariously liable for the negligence of any permissive user, including Driver-Defendant.

5.4 FOURTH CAUSE OF ACTION – RESPONDEAT SUPERIOR (Against Employer-Defendant) (Optional)

27. Plaintiff repeats and realleges ¶¶ 1–26.
28. At the time of the accident, Driver-Defendant was acting within the course and scope of [his/her] employment with [EMPLOYER NAME].
29. Accordingly, [EMPLOYER NAME] is liable for Driver-Defendant’s negligence under the doctrine of respondeat superior.

6. DAMAGES

30. As a direct and proximate result of Defendant(s)’ negligence, Plaintiff sustained serious and permanent personal injuries including but not limited to [DESCRIBE INJURIES].
31. Plaintiff has incurred medical, hospital, rehabilitation, and related expenses in excess of basic economic loss of $50,000, and will continue to incur such expenses in the future.
32. Plaintiff has sustained loss of earnings and impairment of earning capacity and will sustain such losses in the future.
33. Plaintiff has suffered and continues to suffer severe pain, emotional distress, loss of enjoyment of life, and other non-economic damages.
34. No statutory cap limits Plaintiff’s damages under current New York law.
35. Pursuant to C.P.L.R. § 3017(c), Plaintiff does not state a specific dollar amount but alleges that the damages sought exceed the jurisdictional limits of all lower courts that would otherwise have jurisdiction.

7. JURY DEMAND

36. Plaintiff demands a trial by jury on all issues so triable as of right pursuant to N.Y. Const. art. I, § 2 and C.P.L.R. § 4102.

[// GUIDANCE: Arbitration is rarely elected in NY personal-injury matters.
If the parties desire arbitration pursuant to C.P.L.R. § 7501 et seq., insert a conditional arbitration request here and in the “Prayer for Relief.”]

8. PRAYER FOR RELIEF

WHEREFORE, Plaintiff demands judgment against Defendant(s) as follows:
A. On the First Cause of Action, for compensatory damages in an amount to be determined by a jury;
B. On the Second Cause of Action (if pled), for compensatory damages as determined by a jury;
C. On the Third Cause of Action (if pled), for judgment against Owner-Defendant under VTL § 388;
D. On the Fourth Cause of Action (if pled), for judgment against Employer-Defendant under respondeat superior;
E. For prejudgment interest as permitted by law;
F. For costs and disbursements of this action, including statutory fees;
G. For such other and further relief as the Court deems just and proper.

Dated: [CITY], New York
[DATE]

Respectfully submitted,

[ATTORNEY NAME], Esq.
[LAW FIRM NAME]
Attorneys for Plaintiff
[ADDRESS]
[PHONE] | [EMAIL]
NY Bar No.: [BAR NUMBER]

9. VERIFICATION

STATE OF NEW YORK )
) ss.:
COUNTY OF [COUNTY])

[PLAINTIFF NAME], being duly sworn, deposes and says: I am the Plaintiff in the within action; I have read the foregoing VERIFIED COMPLAINT and know the contents thereof; the same is true to my own knowledge, except as to matters therein stated to be alleged upon information and belief, and as to those matters I believe them to be true.

[// GUIDANCE: If Plaintiff is unavailable, the attorney may verify pursuant to C.P.L.R. § 3020(d), or an affirmation may be used under C.P.L.R. § 2106.]

[PLAINTIFF NAME]

Sworn to before me this
day of _, 20___

Notary Public

[// GUIDANCE: BEFORE FILING
1. Review all facts, injuries, and statutory references for accuracy.
2. Attach any required Notice of Claim if a municipal defendant is involved (Gen. Mun. Law §§ 50-e, 50-i).
3. Serve a proper Summons with this Verified Complaint in accordance with C.P.L.R. Art. 3.
4. File the RJI and pay the filing fee when appropriate.
5. Consider early preservation of electronic evidence (spoliation letters).]