On her way to work on Friday, November 12, 2021, Susan Litigant ducked her head against the cold wind and stepped gingerly across the ice patches in front of her home at 6 Newton Avenue, Tewksbury, Mass., to put a letter in her mailbox. Her husband, Lowell Litigant, and their children, Alison, age 9, and Chris, age 12, waited in the car in the Litigant driveway, ready to be dropped off at work and school.

I.M. Hurd, married and the father of three teenage children, sang along with the radio as he drove his ABC Corp. van the morning of November 12th. After delivering this package, he would take a breakfast break. It had not been fun driving in the wind and patchy ice.

The ABC Corp. is located at One Lowell Drive, Bedford, Mass. It is a Massachusetts corporation. Mr. Hurd works at this location.

As the van topped a sharp crest in the road, Mr. Hurd saw a woman on the right side of the road stepping out onto the street. He pressed down on the brake pedal, but the van did not stop.

Mrs. Litigant looked up at the approaching van. Mr. Hurd hit the brake hard. The van skidded. Mrs. Litigant scrambled frantically, in vain. Mr. Hurd could not bring the van under control, and it struck Mrs. Litigant, then smashed into a tree.

Mrs. Litigant suffered a broken leg, was brought to the hospital by ambulance, incurred medical bills, and missed substantial time at work.

Assume you are filing this complaint in state court in Middlesex County in Massachusetts. I will be looking for you to set up the complaint in the proper format -- I do not expect you to do the substantive legal research to have all the legal theories. Just pick one legal theory for the complaint. I am primarily looking to see that you have the format of the complaint set up correctly. The format of the complaint you can copy from the sample posted in Week Five or from the samples in the textbook. I will be checking that all the required parts of the complaint are included. For the plaintiff, you should have just Mrs. Litigant, while you should have as defendants both Mr. Hurd and the ABC Corp. You can use the work address for Mr. Hurd as his address in the complaint.

It also looks better if you double space the complaint, make each paragraph a separate number, and use and formal sentences.

At the bottom of the complaint you can put your own name as if you were the lawyer. You can also put as the date the current date.

You should end up with no more than three pages -- being brief is a virtue, and again the point of this assignment is to get the format and the parts of a complaint right, not to do complex legal research.

########Draft an answer to the complaint you submitted last week. Your answer should have the same format and essentially the same sections as the complaint. You should make some sort of reply to each numbered paragraph of your complaint. You do not need to include a counterclaim or cross-claim.

Imagine you are the paralegal for the attorney representing Mr. Hurd and ABC Corp. Draft the answer from the point of view of that attorney.