Form 13. COMPLAINT FOR NEGLIGENCE UNDER FEDERALEMPLOYERS' LIABILITY ACT (45 U.S.C.A., 51-58)
1. During all the times herein mentioned defendant owned and operated in interstate commerce a railroad which passed through a tunnel located at .... and known as Tunnel No. .....
2. On or about June 1, 1958, defendant was repairing and enlarging the tunnel in order to protect interstate trains and passengers and freight from injury and in order to make the tunnel more conveniently usable for interstate commerce.
3. In the course of thus repairing and enlarging the tunnel on said day defendant employed plaintiff as one of its workers, and negligently put plaintiff to work in a portion of the tunnel which defendant had left unprotected and unsupported.
4. By reason of defendant's negligence in thus putting plaintiff to work in that portion of the tunnel, plaintiff was, while so working pursuant to defendant's orders, struck and crushed by a rock, which fell from the unsupported portion of the tunnel, and was (describing plaintiff's injuries).
5. Prior to these injuries, plaintiff was a strong, able-bodied man, capable of earning and actually earning .... dollars per day. By these injuries the plaintiff has been made incapable of any gainful activity, has suffered great physical and mental pain, and has incurred expense in the amount of .... dollars for medicine, medical attendance and hospitalization.
Wherefore plaintiff demands judgment against defendant in the sum of .... dollars and costs.
History: En. Sec. 80, Ch. 13, L. 1961; amd. Sup. Ct. Ord. May 1, 1990, eff. May 1, 1990.
Structure Montana Code Annotated
Chapter 20. Rules of Civil Procedure
Form 1. SUMMONS -- OFFICIAL FORM
Form 2. COMPLAINT ON A PROMISSORY NOTE
Form 3. COMPLAINT ON AN ACCOUNT
Form 4. COMPLAINT FOR GOODS SOLD AND DELIVERED
Form 5. COMPLAINT FOR MONEY LENT
Form 6. COMPLAINT FOR MONEY PAID BY MISTAKE
Form 7. COMPLAINT FOR MONEY HAD AND RECEIVED
Form 8. COMPLAINT FOR NEGLIGENCE
Form 10. COMPLAINT FOR CONVERSION
Form 11. COMPLAINT FOR SPECIFIC PERFORMANCE OF CONTRACT TO CONVEY LAND
Form 12. COMPLAINT ON CLAIM FOR DEBT AND TO SET ASIDE FRAUDULENT CONVEYANCE UNDER RULE 18(b)
Form 13. COMPLAINT FOR NEGLIGENCE UNDER FEDERAL EMPLOYERS' LIABILITY ACT (45 U.S.C.A., 51-58)
Form 14. COMPLAINT FOR INTERPLEADER AND DECLARATORY RELIEF
Form 16. ANSWER PRESENTING DEFENSES UNDER RULE 12(b)
Form 17. ANSWER TO COMPLAINT SET FORTH IN FORM 7, WITH COUNTERCLAIM FOR INTERPLEADER
Form 18-A. NOTICE OF A LAWSUIT AND REQUEST TO ACKNOWLEDGE AND
Form 18-B. Acknowledgment and Waiver of Service of a Summons
Form 19. MOTION TO INTERVENE AS A DEFENDANT UNDER RULE 24
Form 20. MOTION FOR PRODUCTION, ETC., UNDER RULE 34
Form 21. REQUEST FOR ADMISSION UNDER RULE 36