what is the proper form of a complaint

State of South Carolina County of Richland Sameul Shealy 35 Ross Avenue Columbia, SC 12345 Plaintiff(s) Vs. Harry Stamper Stamper's Oil Rig, Inc. 13 Armageddon Drive Columbia, SC 12345 Defendant(s) Civil Action No.:____-___-____ COMPLAINT For this complaint Plaintiff Sameul Shealy brings forth complaints against Defendant Harry Stamper (Stamper's Oil Rig, Inc.) and alleges the following: I. Nature of the Case 1. I, Plaintiff Samuel Shealy, have accumulated $80,000 in medical bills as well as lost wages of $30,000. His sales have also dropped by 50% because of a wrench falling on his head at Harry Stamper's establishment (Stamper's Oil Rig, Inc.). Stamper bad mouthed Mr. Shealy while he was out of work and in the hospital after the incident occurred. II. The Parties 2. Samuel Shealy is a citizen in Columbia, South Carolina and is located in Richland County. 3. Samuel Shealy resides at 35 Ross Avenue Columbia, SC 12345. 4. Harry Stamper is believed to be a citizen living in Richland County in the city of Columbia. 5. Harry Stamper is the business owner of Stamper's Oil Rig, Inc. 6. Stamper's Oil Rig, Inc. is believed to be located at 13 Armageddon Columbia, SC 12345. III. Jurisdiction and Venue 7. Defendants (Harry Stamper and Stamper's Oil Rig, Inc.) are citizens of the state of South Carolina. 8. Plaintiff, Samuel Shealy, is a citizen of Columbia, SC in Richland County. 9. Samuel Shealy claims damages and hospital bill exceeds $110,000. 10. Venue is proper in the Court of Common Pleas of Richland County. IV. General Allegations 11. Mr. Samuel Shealy sells gym equipment to body builders. 12. Mr. Harry Stamper was a customer of Samuel Shealy. 13. On December 1, 2019, Mr. Shealy visited his customer, Harry Stamper, at Stamper's Oil Rig, Inc. in Richland County. 14. While visiting the oil rig Mr. Shealy walked under an area that Mr. Stamper had been working on, and a large wrench fell from a pipe and fractured the skull of Mr. Shealy. 15. "I am so sorry! This is exactly why our safety standards tell us not to leave the wrenches on pipes" is what was said to Mr. Shealy by Mr. Stamper. This statement was made after the wrench had fractured Mr. Shealy's skull. 16. February 1, 2020, Mr. Shealy left the hospital with medical bills adding up to $80,000. Plus, the money lost in wages coming in at approximately $30,000. As well as, a 50% drop in sales after Mr. Stamper made the comment, "I would never buy gym equipment from a man who doesn't even know how to use it." 17. Mr. Shealy would like to recover damages for his medical bills, lost wages, lost business, and any other damages available to him. V. Causes of Action Count One (Negligence) 18. Mr. Stamper allowed Mr. Shealy into an area that was still being worked on without a hardhat. 19. Mr. Stamper had tools laying around the oil rig that caused damage to Mr. Shealy. 20. Mr. Stamper admitted that during the time of the visit of Mr. Shealy the oil rig was not following safety standards. Mr. Stamper made the comment, "I am so sorry! This is exactly why our safety standards tell us not to leave the wrenches on pipes." Count Two (Defamation) 21. Mr. Stamper told others "I would never buy gym equipment from a man who doesn't even know how to use it." 22. Mr. Stamper bad mouthed Mr. Shealy and the gym equipment business that Mr. Shealy runs. VI. Prayer for Relief Therefore, Samuel Shealy prays that the Court enter judgment against the Defendants: Harry Stamper and Stamper's Oil Rig, Inc. on all counts, providing the following relief: A. Medical bills B. Lost wages C. Lost business D. Any other damages available This the 1st day of January 2021. Law Office of Sarah Jones Sarah Jones (Plaintiff's Attorney) 1234 Main Street Columbia, SC 12345 s..h@joneslaw.co