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Form 15. Complaint for Damages Under Merchant Marine Act
1. Allegation of jurisdiction. [If the pleader wishes to invoke the distinctively maritime procedures referred to in Rule
9
(h), add the following or its substantial equivalent: This is an admiralty or maritime claim within the meaning of Rule
9
(h).]
2. During all the times herein mentioned defendant was the owner of the steamship XXX and used it in the transportation of freight for hire by water in interstate and foreign commerce.
3. During the first part of (month and year) at XXX plaintiff entered the employ of defendant as an able seaman on said steamship under seamen’s articles of customary form for a voyage from XXX ports to the Orient and return at a wage of XXX dollars per month and found, which is equal to a wage of XXX dollars per month as a shore worker.
4. On June 1, 1936, said steamship was about XXX days out of the port of XXX and was being navigated by the master and crew on the return voyage to XXX ports. (Here describe weather conditions and the condition of the ship and state as in an ordinary complaint for personal injuries the negligent conduct of defendant.)
5. By reason of defendant’s negligence in thus (brief statement of defendant’s negligent conduct) and the unseaworthiness of said steamship, plaintiff was (here describe plaintiff’s injuries).
6. Prior to these injuries, plaintiff was a strong, able-bodied man, capable of earning and actually earning XXX dollars per day. By these injuries he has been made incapable of any gainful activity; has suffered great physical and mental pain, and has incurred expense in the amount of XXX dollars for medicine, medical attendance, and hospitalization.
Wherefore plaintiff demands judgment against defendant in the sum of XXX dollars and costs.
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Notes
No Update(s)
Parallel authorities (CFR)
Title 28a RSS
Notes
No Update(s)
Parallel authorities (CFR)
Title 28a RSS
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