Little Jimmy O'Leary, lives in Birmingham, Alabama and works as a law clerk for a federal judge in Mississippi. While Little Jimmy O'Leary hates the humidity of Florida, he owns a vacation home in Marco Island, Florida which he rents out. Over the summer break, Little Jimmy O'Leary decides to visit his father who lives in Marco Island, Florida. While driving on Interstate 75 in Florida, Little Jimmy O'Leary gets into a car accident with Sally Johnson, who owns a vacation home in Florida, but is a resident of New Jersey. As a result of the accident, Little Jimmy O'Leary suffers serious injuries and a totaled car. In addition to severe brain injuries, Little Jimmy O'Leary loses all use of his right arm. Sally Johnson suffers no serious medical injuries, but her Fiat 500 suffers over $5,000 in damages. After recovering from his injuries, Little Jimmy O'Leary returns home to Alabama. Because Little Jimmy O'Leary cannot type with his right hand, he loses his job as a law clerk.

Assume that you are working as a paralegal at a law firm representing Jimmy. Your assigning attorney asked you to draft a draft of a complaint for the firm's client (Jimmy). Using your readings and any sample complaints that you can find on-line, please create a draft complaint for your assigning attorney's review. Please make sure that your draft complaint includes a jurisdictional statement as well a claim for damages.

Assume that you were a paralegal working in the law firm representing Jimmy. Discuss the mechanics of filing the complaint that you drafted in Part I of this forum. For example, discuss where a complaint should be filed and who should be included in the Certificate of Service? How would you serve the complaint you drafted in Part I on Sally pursuant to the applicable service rules?