For this paralegal certificate assignment, I drafted a complaint for Brown from the fictional account in our textbook, “The Legal Odyssey of Michael Brown: An Anatomy of the Litigation Process.”
UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CASE NO.:
MICHAEL BROWN,
Plaintiff,
vs.
GEORGE MILLER, and
THE ESTATE OF HAROLD CLAY,
Defendants.
____________________________________/
COMPLAINT FOR A MOTOR VEHICLE CIVIL CASE ALLEGING NEGLIGENCE AND DEMAND FOR JURY TRIAL
COMES NOW the Plaintiff, MICHAEL BROWN, by and through his undersigned attorney, and sues Defendants GEORGE MILLER and THE ESTATE OF HAROLD CLAY, and alleges:
- This is an action for damages in excess of $100,000.00, exclusive of costs, interest, and attorney’s fees.
FACTS
- The United States District Court for the Middle District of Florida, Orlando, has subject matter jurisdiction pursuant to diversity of citizenship under 28 U.S.C. § 1332, as Plaintiff and Defendants are residents of different states and the amount in controversy exceeds $75,000.
- Venue is proper in this Court because the Plaintiff resides in this district and the injuries giving rise to this action affected the Plaintiff within this jurisdiction.
- On or about a date several years ago, Plaintiff MICHAEL BROWN was walking home from work.
- At that time, HAROLD CLAY, an acquaintance and former friend of Plaintiff, stopped and offered Plaintiff a ride home.
- Plaintiff accepted the ride and entered the vehicle as a passenger.
- While Defendant HAROLD CLAY was driving, Plaintiff and Clay were engaged in conversation.
- After traveling several blocks, Defendant GEORGE MILLER negligently operated his vehicle and ran a red light.
- Defendant GEORGE MILLER'S vehicle struck the vehicle driven by HAROLD CLAY.
- As a result of the collision, Plaintiff MICHAEL BROWN sustained serious injuries.
- Defendant HAROLD CLAY also sustained injuries and later died approximately two weeks after the accident as a result of those injuries.
- At all times material hereto, Defendant GEORGE MILLER had a duty to operate his motor vehicle in a safe and reasonable manner.
- Defendant GEORGE MILLER breached that duty by running a red light and failing to maintain proper control of his vehicle.
- At all times material hereto, Defendant HAROLD CLAY also had a duty to operate his vehicle safely and exercise reasonable care.
- Defendant HAROLD CLAY breached that duty by failing to operate his vehicle safely under the circumstances.
- As a direct and proximate result of Defendants’ negligence, Plaintiff suffered severe injuries and damages.
COUNT I
NEGLIGENCE AGAINST DEFENDANT GEORGE MILLER
- Plaintiff realleges paragraphs 1 through 16 as if fully set forth herein.
- Defendant GEORGE MILLER owed a duty of care to Plaintiff.
- Defendant GEORGE MILLER breached that duty by negligently operating his vehicle, including but not limited to running a red light.
- As a direct and proximate result of Defendant’s negligence, Plaintiff sustained bodily injury including a permanent injury to the body as whole, pain and suffering both physical and mental, disability, physical impairment, mental aguish, inconveicne, loss of enjoyment of life, medical expenses, loss of earnings, loss of future earnings, loss of ability to lead and enjoy a normal life. The losses are permanent and ongoing, and Plaintiff will suffer further losses in the future.
COUNT II
NEGLIGENCE AGAINST THE ESTATE OF HAROLD CLAY
- Plaintiff realleges paragraphs 1 through 16 as if fully set forth herein.
- Defendant HAROLD CLAY owed a duty of care to Plaintiff.
- Defendant HAROLD CLAY breached that duty by negligently operating his vehicle.
- As a direct and proximate result of Defendant’s negligence, Plaintiff sustained injuries and damages. As a direct and proximate result of Defendant’s negligence, Plaintiff sustained bodily injury including a permanent injury to the body as whole, pain and suffering both physical and mental, disability, physical impairment, mental aguish, inconveicne, loss of enjoyment of life, medical expenses, loss of earnings, loss of future earnings, loss of ability to lead and enjoy a normal life. The losses are permanent and ongoing, and Plaintiff will suffer further losses in the future.
PRAYER FOR RELIEF
- WHEREFORE, Plaintiff MICHAEL BROWN demands judgment for damages in the amount of $100,000.00 each, plus costs, prejudgment interest, and other relief this Court deems appropriate against the Defendants, GEORGE MILLER and THE ESTATE OF HAROLD CLAY.
DEMAND FOR JURY TRIAL
- Plaintiff demands trial by jury on all issues so triable.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via United States District Court for the Middle District of Florida, Orlando E-filing Portal upon said Defendants,
/s/Brenda Davis
Brenda Davis, Esquire
Florida Bar No. 12345678
Davis & Davis, P.A.
123 Main Street
Melbourne, FL 32901
Telephone: (321) 555-1234
Facsimile: (321) 555-4321
Email: bdavis@davisanddavislaw.com
Attorney for the Plaintiff
References
“28 U.S. Code § 1332 – Diversity of citizenship; amount in controversy; costs.” LII / Legal Information Institute, www.law.cornell.edu/uscode/text/28/1332.
All Forms – Filing a Case Forms | Middle District of Florida | United States District Court. www.flmd.uscourts.gov/forms/all/filing-a-case-forms.
All Forms – Litigants without Lawyers Forms | Middle District of Florida | United States District Court. www.flmd.uscourts.gov/forms/all/litigants-without-lawyers-forms.
Complaint, Williams v. Carroll, Brevard County Filing No. 238463504 (filed Dec.. 29, 2025)
“Federal Rules of Civil Procedure.” LII / Legal Information Institute, www.law.cornell.edu/rules/frcp.
“—.” United States Courts, www.uscourts.gov/forms-rules/current-rules-practice-procedure/federal-rules-civil-procedure.
Filing a Case | Middle District of Florida | United States District Court. www.flmd.uscourts.gov/filing-case.
“Florida Rules of Court Procedure.” The Florida Bar, 2 Apr. 2026, www.floridabar.org/rules/ctproc.
Local Rules | Middle District of Florida | United States District Court. www.flmd.uscourts.gov/local-rules/filing-a-case.
“Rule 7. Pleadings Allowed; Form of Motions and Other Papers.” LII / Legal Information Institute, www.law.cornell.edu/rules/frcp/rule_7.
“Rule 8. General Rules of Pleading.” LII / Legal Information Institute, www.law.cornell.edu/rules/frcp/rule_8.