1Name: First, Last

Street or Mailing Address

City, State, Zip
Telephone
IN PRO SE

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF [PUT NAME OF DISTRICT HERE]

Name )
Plaintiff, )
) COMPLAINT
vs )
) NO.
[SUPPLIED TO YOU BY THE COURT]
)
)
Name (s) )
[Does 1-100 [if additional )
Defendants are unknown] )
Defendants )
________________________)

INTRODUCTION
1) This action seeks monetary relief [or injunctive, or declatory, see different types of relief

sought] from the defendants for [specify what action the relief is sought for].

JURISDICTION AND VENUE

2) Allege here that the court has jurisdiction to hear the matter pursuant to 28 U.S.C. 1331

[which is a federal question - that the defendant broke a federal law which is found in the United

States Code]. The court also has subject matter jurisdiction pursuant to 28 U.S.C. 1332 [this code

is used if the defendant and the plaintiff are citizens of different states or countries. Careful here

when suing a business. There are standards in which the court must weigh in determining

diversity jurisdiction - please look to the general laws in determining the home place of business
when suing a business. The jurisdictional amount of suit here is $75,000. Check this frequently,

as the laws may change]. The court has supplemental jurisdiction pursuant to 28 U.S.C. 1367

to hear Plaintiffs state law claims because those claims are related to Plaintiff’s federal claims and

are inextricably entwined [use this if there are state law claims such as emotional distress and the

like, which are a result of the breaking of federal laws] and arise out of a common nucleus of

related facts. Plaintiff’s state law claims are related to Plaintiff’s federal law claims such that

those claims form part of the same case of controversy under Article III of the United States

Constitution. Venue is proper in that the claims alleged here arose due to the Plaintiffs residence

within the Northern District of [ Federal District Name]

PARTIES

4) Describe the each of the parties - Plaintiffs first [ex. Plaintiff is a disabled American harmed by

the defendant(s) and is acting in pro-se (always put Latin phrases in italics)].

FACTS

5) Allege all the facts here, in date order, (no need to bulletize, but put in numbered paragraphs

when deemed necessary) that led up to the complaint. Include here the history of the relationship

between you and the defendants and what gave rise to the defendant’s federal tort. [ ex. Plaintiff

John Doe of San Jose, CA., entered in a contract with Joe Shmoe in New York, NY, and that

contract resulted in a breach by that defendant. That breach is as follows: Story tell but don’t get

too intricate]

INJURIES

7) By reason of defendants outrageous acts, the acts perpetrated by defendant would cause

susceptibility to emotional distress and physical injury and mental anguish, including but not

limited to bodily injury such as stomach aces, sleep loss, feelings of worthlessness and increase in
medication, feelings of depression anger and irritability and appetite loss. Accordingly plaintiff is

entitled to special damages.

FIRST CLAIM

SEVERE EMOTIONAL DISTRESS

8) Plaintiff realleges and incorporates paragraphs 1-7 of the complaint herein.

9) By reason of defendants outrageous acts, and knowledge of Plaintiffs closed head injury that

would cause susceptibility to emotional distress and physical injury and mental anguish, including

but not limited to bodily injury such as stomach aces, sleep loss, feelings of worthlessness and

increase in medication, feelings of depression anger and irritability and appetite loss. Accordingly

plaintiff is entitled to special damages.

SECOND CLAIM

INTENTIONAL AND RECKLESS DISREGARD

10) Plaintiff realleges and incorporates paragraphs 1-9 of the complaint herein.

11) Defendants acted with the intent to inflict injury and with the realization that an injury was

substantially certain to result from their conduct. Knowledge of Plaintiffs closed head injury that

would cause susceptibility to emotional distress and physical injury and mental anguish, including

but not limited to bodily injury such as stomach aces, sleep loss, feelings of worthlessness and

increase in medication, feelings of depression anger and irritability and appetite loss. Accordingly

plaintiff is entitled to special damages.

 THIRD CLAIM

OUTRAGEOUS CONDUCT

12) Plaintiff realleges and incorporates paragraphs 1-11 of the complaint herein

13) By defendants [allege conduct] the conduct is so outrageous that it exceeds all bounds of

common decency usually tolerated by a civilized society. Knowledge of Plaintiffs closed head

injury the would cause susceptibility to emotional distress and physical injury and mental

anguish, including but not limited to bodily injury such as stomach aces, sleep loss, feelings of

worthlessness and increase in medication, feelings of depression anger and irritability and appetite

loss. Accordingly plaintiff is entitled to special damages.

FOURTH CLAIM

NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

14) Plaintiff realleges and incorporates paragraphs 1-13 of the complaint herein.

15) Injuries were proximately caused by the Defendants by their negligent conduct and willful

violation of a statutory claim, it cause would cause susceptibility to emotional distress and

physical injury and mental anguish, including but not limited to bodily injury such as stomach

aces, sleep loss, feelings of worthlessness and increase in medication, feelings of depression anger

and irritability and appetite loss. Accordingly plaintiff is entitled to special damages.
 FIFTH CLAIM

ABUSE OF PROCESS

16) Plaintiff realleges and incorporates paragraphs 1-14 of the complaint herein.

17) Defendants, with malice, used the legal process to accomplish a purpose for which it was not

designated. Knowledge of Plaintiffs condition would cause susceptibility to emotional distress

and physical injury and mental anguish, including but not limited to bodily injury such as stomach

aces, sleep loss, feelings of worthlessness and increase in medication, feelings of depression anger

and irritability and appetite loss. Accordingly plaintiff is entitled to special damages.

PRAYER FOR RELIEF

WHEREFORE Plaintiff [name] prays for entry of judgement against the Defendants

that:

1) Compensatory damages in the amount of $150,000;

2) Special damages (punitive) in the amount of $100,000;

3) that all costs of suit herein be awarded;

4) such other and further relief as the court may deem just and proper.

Respectfully submitted

This _____day of April 2002

____________________________

[Name]

IN PRO PER