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Complain Letter

Student name

Professor’s name

Institution

Date
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Name

City, State, Zip Code

Phone Number

Email Address

Today's Date

Clerk of the Court Colebrook c/o 55 School Street [Mississippi,, Southern State , 38655]

Re: Gloria McMillen v. Rebecca Morse Case Number:

Dear Clerk of the Court,

Enclosed are the original and three copies of the letter of complaint on the matters

mentioned above that are clear for filing in court. We request that you file the enclosed

documents and return a file-stamped copy for the undersigned.

Thank you for your attention to this matter.

Sincerely

Name

IN THE CIRCUIT COURT FOR Oxford Lafayette, MISSISSIPPI GLORIA MCMILLEN

Plaintiff

v.

REBECCA MORSE Defendant

COMPLAINT

COMES NOW Plaintiff Gloria McMillen, by and through her undersigned counsel, files

this complaint on the damages made by Rebecca Morse, the defendant in this case and makes the

following allegations.

PARTIES
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1. Plaintiff Gloria McMillen, as a citizen and resident, is currently

maintaining her residence located at 216 Price Stress addresses, which is in Apartment

#15 Building G, located in the Hub residential community located in the city of Oxford,

Mississippi, zip code 386555. The address that has been mentioned is a primary domicile

and the legally granted residence of Plaintiff McMillen.

2. On the other hand, defendant Rebecca Morse is a resident of the geographical confines of

Oxford, Mississippi, which is one of the principal places of residence and legal domicile.

The defendant, Rebecca Morse, resides in Oxford, Mississippi, with a zip code of 38655,

making her serve as the principal place she is receding and hence the legal domicile.

JURISDICTION AND VENUE

3. According to the Complains Act of 1985 existing state owned and regulated legal

precedent and statutory provisions, the county court is as a honorable court remains

steadfast on the rightful jurisdiction. Based on the statutory provisions on the issues,

authorities of the tribunal are well established to meet the existing conferring; hence,

conferring on the Court the existing power and jurisdiction necessary for adjudication

(Mulcahy & Lloyd-Bostock, 2022). The subject under consideration took place in an area

that was a jurisdiction of the Southern States, Mississippi, hence implying that the venue

is effectively situated in the designated jurisdiction for the required dispensation that is

associated with justice based on well-established legal precepts and the expected

protocols for procedures.

4. The venue is effectively vested in the jurisdiction of Oxford-Lafayette County,

Mississippi and the applicable root cause of the action leading to the emergence of the

existing legal proceedings that occurred in the area as far as the designated jurisdiction
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for the case is concerned. As a main subject, this litigation occurred in the territorial

boundaries of the Southern State County, Mississippi; hence creating an opportunity for

effective designation of the jurisdiction as far as the dispensation of justice is concerned

using the created legal precepts as well as procedural protocols.

FACTS

5. It is clear that on 3 November, Gloria McMillan, the plaintiff, started a journey where he

was travelling in the easterly direction and was using Jackson Avenue, which is located

in Oxford, Mississippi. The decision to be on the street was a result of the existing traffic

on the roads at that time. The destination that she was travelling to was her workplace in

the human resource department at the University of Mississippi.

6. McMillen was made to mind the congestion that was available on the roadways that led

her to conscientiously slow acceleration of her car with the objective of undertaking a

right turn so as to access the vicinity that was nearby, the Starbucks Coffee shop that had

been strategically positioned on the avenue in the limits of the Oxford. The existing

traffic levels drove the decision to manoeuvre at the prevailing place and time.

7. Coincidentally, Rebecca Morse, the defendant, was also in her vehicle going through in

the easterly direction using Jackson Avenue, which happened to be the same

thoroughfare that McMillen, the plaintiff, used. Nevertheless, due to the grievous lapse of

attention, the defendant was unable or failed to consider the congested traffic pattern that

was present at the egress and ingress points in the vicinity where Starbucks is located.

The impact was that she carelessly collided with the car at its rear end of McMillen’s car,

causing substantial force and, thus, damage to the car and her health.
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8. The impact of forceful impact was multiple and immediate to Gloria McMillen, the

plaintiff in the case. She suffered grievous bodily harm, which comprises of the tendon

damage of the left hand. She was forced to undergo immediate medical attention and,

thereby, hospitalization. After the discharge, she endured an arduous, well-proacted

course in physical therapy to help heal the situation, thus solving the debilitating harm to

her. Currently, she has continued to struggle with the aftermath of the accident, requiring

her to continuously seek medical help from time to time as well as rehabilitation.

9. The treatment and recovery lead to the plaintiff's accident from her gainful employment.

Another impact is the compelling and distressing hiatus from professional duties, creating

more agony that took place for more than six months. She was required to undergo the

entire treatment process, and debilitating injuries were acquired from the impact. Also,

the car she was using that was involved in the accident, Chevrolet Equinox, was rendered

damaged and hence considered a written-off as indicated by the insurance company.

10. Despite efforts made to compensate her by the insurance company, which have gone

futile, McMillen has found herself bereft of the reliable transportation that occurred after

the collision. While the compensation has been made, more is needed to overcome

existing challenges, causing hardships and leaving McMillan in a vexing predicament of

acquiring alternative means of transportation.

11. The events that were caused by the culmination of the collision were terrific to the extent

of creating motion using negligent and heedless activities and actions Defendant Rebecca

Morse has been involved in. Her wanton disregard for the need to uphold safety and safe

driving to protect others using the road makes her as a person has failed to uphold the
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requisite degree of care and vigilance that is required by all users of roads, hence directly

leading to the collision that has left the plaintiff with more harm enduring hardships.

COUNT I – NEGLIGENCE

12. Plaintiff thus continually reaffirms and adopts using relegation and incorporation by

reference to all preceding allegations that are made in the 1st and 11th paragraphs.

13. It is demanded that Rebecca Morse, the defendant, has a duty to enhance the safety and

care of Gloria McMillen by driving in a careful manner that is compliant with the

expectations, standards, and traffic rules.

14. McMillen contends that the defendant violated the duty, failing to maintain a proper

lookout and neglecting the role of applying the brakes in a timely manner despite having

seen the risks caused by the traffic that would have prevented the collision.

15. The plaintiff argues that the defendant's breach, as mentioned above, of duty directly as

well as proximate, resulted in a subject accident and consequent harm experienced by the

plaintiff (Turakulova, & Turaeva, 2023). The failure to meet the requisite standard of

care established using the existing unreasonably risky situation led to the accident,

leading to the liable for the resulting damages.

16. The direct and proximate consequence of the defendant's action was that the plaintiff

suffered comprehensive physical injuries and pain as well as suffering that led to the

existing medical expenses for the required treatment as well as rehabilitation and the

losses incurred based on the salaries in the recovery and the damages. These are all tied

to negligence and constitute a foundation using the relief in the action.

WHEREFORE, Plaintiff Gloria McMillen wants judgment against the defendant in an

amount to be determined for trial and other costs incurred as interest, as well as costs and other

benefits that the court will deem proper and just.

Respectfully submitted,

Your Name

Your Address

City, State, Zip Code

Phone Number

Email Address

CERTIFICATE OF SERVICE

I, as a result of this, certify that a true and correct copy of the previous complaint has

been served on the defendant's attorney, if known, or on the defendant personally, on this [date],

by [method of service].

Your Name
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References

Mulcahy, L., & Lloyd-Bostock, S. (2022). Complaining–what's the use?. In Quality and

Regulation in Health Care (pp. 51-68). Routledge.

Turakulova, P., & Turaeva, U. (2023). THE MAIN METHODS OF WRITING COMPLAINT

LETTER. Центральноазиатский журнал образования и инноваций, 2(11 Part 2), 112-

114.