Annotated samples

Three complete sample complaints for common kinds of New York City car accidents. Each one shows the sample text on the left and a general note on the right explaining what each paragraph is for. The samples share many paragraphs; the notes point out what changes from one kind of accident to another.

• Two vehicles Two-vehicle rear-end collision

  A stopped car is struck from behind by a car whose driver also owns it. One plaintiff sues one defendant for personal injuries and for the damage to the car.

• Three or more vehicles Three-vehicle chain collision

  A stopped car at the front of a line is struck in a chain collision involving two cars behind it. One plaintiff sues both other drivers, each of whom owns the car he or she was driving.

• Pedestrian Pedestrian struck in a crosswalk

  A pedestrian crossing in a marked crosswalk is knocked down by a car whose driver also owns it. One plaintiff sues one defendant for personal injuries.

Reading these samples

• The left column is sample text. Words in brackets, like [plaintiff's full name], are blanks. Everything else is the sample wording, which may or may not fit a particular accident.
• The right column explains, in general terms, what each paragraph is for and which rules it relates to. It is the same for every reader and does not say whether any paragraph fits a particular case.
• Each sample fits only the situation described at its top. Paragraphs for other situations, such as passengers, intersections, city vehicles, rideshares, and family members' claims, are in the paragraph catalog.
• Several rules for car accident lawsuits changed for cases started on or after May 26, 2026. The notes describe the rules for those cases; complaints filed earlier, including ones viewed in the court's filing system, may reflect the older rules.

Last reviewed October 2026. Sample text is general and may be out of date.