IN THE CIRCUIT COURT OF THE STATE OF OREGON

FOR THE COUNTY OF [COUNTY]

[PLAINTIFF FULL LEGAL NAME],

an individual,
Plaintiff,

v.

[DEFENDANT 1 LEGAL NAME],

a [state] [type of entity], and

[DEFENDANT 2 LEGAL NAME],

a [state] [type of entity],
Defendants.

COMPLAINT (PERSONAL INJURY – NEGLIGENCE)
JURY TRIAL DEMANDED
(Claim: ** $[AMOUNT]** – Subject to applicable Oregon statutory damages limitations)

[// GUIDANCE: Oregon Uniform Trial Court Rules (UTCR) require the “Claim” notation on the first page when a party seeks money damages. Insert “CLAIM IS $10,000 OR MORE” or “CLAIM IS LESS THAN $10,000,” as appropriate.]

TABLE OF CONTENTS

1. INTRODUCTORY ALLEGATIONS
2. DEFINITIONS
3. PARTIES, JURISDICTION, AND VENUE
4. FACTUAL ALLEGATIONS
5. FIRST CLAIM FOR RELIEF – NEGLIGENCE
6. DAMAGES
7. JOINT AND SEVERAL LIABILITY ALLEGATIONS
8. PRAYER FOR RELIEF
9. DEMAND FOR JURY TRIAL
10. PRESERVATION OF EVIDENCE
11. GENERAL RESERVATIONS
12. VERIFICATION & SIGNATURE BLOCK

1. INTRODUCTORY ALLEGATIONS

1.1 Plaintiff brings this action for personal injuries arising out of Defendants’ negligent acts and omissions that occurred on or about [DATE] at or near [LOCATION] in the State of Oregon.

1.2 Plaintiff seeks all legally recoverable economic and non-economic damages, subject to any constitutionally valid statutory caps, together with costs, disbursements, pre- and post-judgment interest, and such other relief as the Court deems just and proper.

2. DEFINITIONS

For purposes of this Complaint, the following terms have the meanings set forth below:

“Accident” means the incident occurring on [DATE] described in Section 4.
“Economic Damages” means objectively verifiable monetary losses including, without limitation, medical expenses, loss of income, and loss of future earning capacity.
“Non-Economic Damages” means subjective, non-monetary losses including pain, mental suffering, emotional distress, inconvenience, and loss of enjoyment of life, subject to any applicable statutory limitations.
“Plaintiff” means [PLAINTIFF FULL NAME].
“Defendants” means [DEFENDANT 1] and [DEFENDANT 2], individually and collectively.
[// GUIDANCE: Revise, add, or delete defined terms to match the facts of the case.]

3. PARTIES, JURISDICTION, AND VENUE

3.1 Plaintiff is, and at all material times was, a resident of [COUNTY] County, Oregon.

3.2 Defendant 1 is a [corporation/LLC/etc.] organized under the laws of [STATE] with its principal place of business in [STATE] and doing business in Oregon.

3.3 Defendant 2 is a [individual/corporation/etc.] who resides in or conducts business in Oregon.

3.4 The amount in controversy exceeds $10,000, exclusive of interest, costs, and attorney fees.

3.5 This Court has subject-matter jurisdiction under Oregon Constitution Article VII (Amended) and ORS Chapter [INSERT]. Venue is proper in this County because the acts and omissions complained of occurred in, and Defendants conduct business or reside in, this County.

4. FACTUAL ALLEGATIONS

4.1 On [DATE], at approximately [TIME] a.m./p.m., Plaintiff was [describe what Plaintiff was doing—e.g., “operating a motor vehicle in the eastbound lane of Highway XX”].

4.2 Defendant 1, by and through its employee [NAME], was [describe conduct].

4.3 Defendant 2 was [describe separate or additional conduct].

4.4 As a direct and proximate result of Defendants’ acts and omissions described herein, the Accident occurred, causing Plaintiff to sustain severe bodily injuries, including but not limited to [list injuries], together with resultant economic and non-economic damages.

5. FIRST CLAIM FOR RELIEF – NEGLIGENCE

5.1 Plaintiff realleges and incorporates by reference Sections 1 through 4.

5.2 Duty. Defendants owed Plaintiff the duty to exercise reasonable care under the circumstances to avoid foreseeable risk of harm.

5.3 Breach. Defendants breached that duty by, inter alia:
 a. [Specify negligent act—e.g., “operating a motor vehicle at an unsafe speed”];
 b. [Identify additional breaches]; and
 c. Failing to comply with applicable statutes, regulations, and industry standards.

5.4 Causation. Defendants’ breaches were a substantial factor in causing the Accident and Plaintiff’s resulting injuries.

5.5 Damages. Plaintiff suffered the damages described in Section 6.

[// GUIDANCE: Where statutory negligence per se is alleged, identify the violated statute and its protective purpose.]

6. DAMAGES

6.1 Economic Damages. Plaintiff has incurred past economic damages of approximately $[AMOUNT] and will incur future economic damages of approximately $[AMOUNT].

6.2 Non-Economic Damages. Plaintiff seeks non-economic damages in an amount to be determined at trial, but not to exceed any constitutionally valid statutory limitation under Oregon law.

6.3 Plaintiff reserves the right to amend these amounts consistent with ORCP 23 as discovery progresses.

7. JOINT AND SEVERAL LIABILITY ALLEGATIONS

7.1 Defendants’ negligence combined to cause an indivisible injury to Plaintiff.

7.2 Under Oregon’s modified joint-and-several liability framework, Defendants are jointly and severally liable for Plaintiff’s economic damages and severally liable, in proportion to their respective fault, for Plaintiff’s non-economic damages.

[// GUIDANCE: Oregon law currently imposes joint liability for economic damages only. Confirm latest statutory language and constitutional rulings.]

8. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully prays for judgment against Defendants, and each of them, as follows:

A. Economic damages in the sum of $[AMOUNT] or as proven at trial;
B. Non-economic damages in an amount to be determined at trial, subject to any applicable statutory cap;
C. Pre-judgment interest at the statutory rate from the date of the Accident until judgment;
D. Post-judgment interest at the statutory rate until paid;
E. Plaintiff’s costs, disbursements, and reasonable attorney fees as allowed by law; and
F. Such other and further relief as the Court deems just and proper.

9. DEMAND FOR JURY TRIAL

Pursuant to Article I, Section 17 of the Oregon Constitution and ORCP 56, Plaintiff demands a trial by jury on all issues so triable.

10. PRESERVATION OF EVIDENCE

10.1 Plaintiff hereby demands that Defendants preserve all evidence, whether in paper, electronic, digital, or any other form, relating to the Accident and Plaintiff’s claims.

[// GUIDANCE: Consider sending a separate litigation-hold letter to prevent spoliation.]

11. GENERAL RESERVATIONS

11.1 Plaintiff reserves the right to amend this Complaint to conform to the evidence, add additional parties or claims, and seek punitive damages if later warranted and permitted by law.

12. VERIFICATION & SIGNATURE BLOCK

I certify that the foregoing is true and correct to the best of my knowledge, information, and belief, and that I have complied with the requirements of ORCP 17.

DATED: [DATE]

Respectfully submitted,

[LAW FIRM NAME]
By: ______
[ATTORNEY NAME] (OSB No. [______])
Attorneys for Plaintiff
[Address]
[Phone]
[Email]

[// GUIDANCE: Insert notarization or witness block only if required for specific claims (e.g., wrongful death beneficiaries). Oregon civil complaints generally do not require notarization.]