Complaint for personal injury compensation disputes

Mondo Social Updated on 2024-03-08

Complaint.

Plaintiff: **female, *ethnicity, born on the day of **month**, 20**, address: **city**district**road**, household registration**province**city**district**number, ID number***

Defendant: **University.

Residence: **City**District**Road**.

Person in charge: **Principal.

Please ask for a thing.

1. Order the defendant to compensate the plaintiff for disability compensation, spiritual solace, escort expenses, food allowance during hospitalization, nutrition expenses and other expenses, and the specific amount will be added separately according to the conclusion of the judicial appraisal (the amount is tentatively set at 10,000 yuan).

2. The defendant shall bear the litigation costs.

Facts & Reasons.

The plaintiff is a student at the medical school of **University and is currently studying at the campus of **University**. At around noon on the 20th month, the defendant replaced the student dormitory with a new bed, and without any protection, the worker threw the bed board downstairs directly from the window and hit the plaintiff's head who was walking normally downstairs, causing the plaintiff to suffer a comminuted fracture of the right parietal bone and lose consciousness on the spot. The plaintiff was sent to *** hospital by his classmates, where he was diagnosed with a right frontal lobe contusion and laceration, a comminuted depression fracture of the right parietal bone, etc. On the same day, ** hospital performed "debridement and removal of comminuted depressed fracture fragments of the right parietal bone" for the plaintiff. On the 20th day of the year, the plaintiff was discharged from the hospital. On 20**/**/**, the plaintiff was hospitalized again in ** hospital, underwent a second operation of "right parietal osteoplasty", and was discharged from the hospital on **/20**.

The defendant ** University paid the plaintiff's medical expenses and part of the accompanying expenses during his hospitalization.

During the plaintiff's study at the defendant ** university, the construction personnel of ** university dismantled the bed board of the dormitory and threw it directly from the window on the fourth floor to the downstairs, and there were no warning measures near the scene, no warning signs were set up, and no guard personnel were arranged, which directly caused the plaintiff to be hit by the floor slab thrown from a height and suffer a head injury. Therefore, the defendant should be liable for compensation in accordance with the law.

The people's courts are requested to make judgments in accordance with law.

Sincerely. *City** District People's Court.

Prosecutor: 2023

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