1.Allegation of jurisdiction.
2.__________（m,d,y）, in a public highway called____ Street in ________, ______, defendant negligently drove a motor vehicle against p0laintiff who was then crossing said highway.
3.As a result plaintiff was thrown down and had his leg broken and was otherwise injured, was prevented from transacting his business, suffered great pain of body and mind , and incurred expenses for medical attention and hospitalization in the sum of_________ dollars.
Wherefore plaintiff demands judgment against defendant in the sum of __________ dollars and costs.
（NOTE: Since contributory negligence is an affirmative defense ,the complaint need contain no allegation of due care of plaintiff.）
