INSTRUCTIONS
You represent the Plaintiff, Gloria McMillen. Gloria resides in Oxford, Mississippi and has been involved in a motor vehicle accident (see additional facts below). You are to submit a printed complaint, ready to be filed with the clerk of the court and the appropriate clerk letter.
You are expected to research all aspects of this case in order to comply with Rule 11 of the MRCP and the Litigation Accountability Act. Your goal is to have a concise but thorough complaint that will prevent you from defending a motion to dismiss or a motion for a more definite statement.
You will be graded on correct form, grammar, and content of the Complaint. You may NOT submit your document electronically. The ONLY way to submit the Complaint is in print form by the deadline listed in your schedule.
COMPLAINT FACTS
Your initial investigation has determined the following:
The Facts
On the morning of November 3, 2020, Ms. Gloria McMillen (the client) was traveling in an easterly direction on Jackson Avenue in Oxford Mississippi. She was on her way to her job in human resources at the University of Mississippi. Ms. McMillen, knowing that today would be particularly stressful, decided to take the edge off the morning by indulging in her favorite beverage. Accordingly, she slowed to turn right into the Starbucks coffee shop located on Jackson Avenue in Oxford Mississippi. Noticing that Starbucks was busy and a line of vehicles had formed out and into Jackson Avenue, Ms. McMillen turned on her signal, stopped and began waiting for the line of cars to move. Meanwhile, the defendant Rebecca Morse was also traveling in an easterly direction on Jackson Avenue. Ms. Morse failed to see the traffic around the Starbucks entrance and although she applied her brakes at the last minute, she struck Ms. McMillen’s Chevy Equinox from behind.
Emergency personnel were called and due to the injuries she received, Gloria spent several days in the hospital, had to undergo lengthy physical therapy and still wears a brace on her left hand due to tendon damage. She missed approximately six (6) months of work, her Chevy Equinox was totaled and she has been depressed for the last several months. Her insurance carrier paid her “something” for her vehicle loss but she still is without a reliable car. Since Rebecca Morse’s insurance company was never serious about taking responsibility for the accident, Gloria has come to you for help. You have agreed to sue the responsible party for damages and will ‘front” the necessary expenses for filing the complaint.
ADDRESSES OF THE PARTIES
Gloria McMillen​Rebecca Morse
216 Price Street​#15, Bldg G The Hub
Oxford, Mississippi 38655 ​Oxford, Mississippi 38655