User Name: IB1BillyBob4U@gmail.

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Date and Time: Wednesday, November 23, 2022 12:10:00 AM EST
Job Number: 184671119

Documents (21)

1. Form 8:147 Complaint in Libel Per Se—General Form

Client/Matter: -None-
2. Form 8:148 Complaint in Libel Per Se—Another Form
Client/Matter: -None-
3. Form 8:149 Complaint for Libel Per Quod
Client/Matter: -None-
4. Form 8:150 Complaint in Libel Per Se Charging Actual Malice
Client/Matter: -None-
5. Form 8:151 Complaint in Libel Per Se for Publication Which May Be Qualifiedly Privileged
Client/Matter: -None-
6. Form 8:154 Complaint in Libel Per Se for Publication Injuring Professional Reputation
Client/Matter: -None-
7. Form 8:153 Complaint in Libel Where Extrinsic Facts Are Pleaded to Establish Innuendo and That Publication
Was Libelous
Client/Matter: -None-
8. Form 8:158 Complaint for Libel and Slander and Conspiracy to Defame—Against Some John Doe
Defendants
Client/Matter: -None-
9. Form 8:159 Complaint for Slander Per Se
Client/Matter: -None-
10. Form 8:160 Complaint for Slander Per Quod
Client/Matter: -None-
11. Form 8:161 Complaint in Libel Per Se Where Extrinsic Facts Must Be Pleaded to Explain Defamation
Client/Matter: -None-
12. Form 8:162 Complaint on Slander of Title of Real Property
Client/Matter: -None-
13. Form 8:174 Complaint for Malicious Prosecution—General Form
Client/Matter: -None-
14. Form 8:175 Complaint for Malicious Prosecution Where Plaintiff Waived Examination and Furnished Bail
Client/Matter: -None-
15. Form 8:176 Complaint for Malicious Prosecution Based on Order of Arrest in Civil Action
Client/Matter: -None-
16. Form 8:173 Complaint for False Imprisonment Where Store Employees Arrest and Search Person for
Shoplifting
Client/Matter: -None-

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17. Form 8:177 Complaint for False Imprisonment, Malicious Prosecution, and Assault
Client/Matter: -None-
18. Form 8:177A Complaint for Abuse of Process and Malicious Civil Prosecution
Client/Matter: -None-
19. Form 8:178 Complaint for Personal Injuries Under Federal Employers’ Liability Act
Client/Matter: -None-
20. Form 8:179 Complaint for Death of Employee Under Federal Employers’ Liability Act
Client/Matter: -None-
21. Form 8:180 Complaint for Injuries Under FELA and Safety Appliance Act
Client/Matter: -None-

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 LexisNexis(R) Forms FORM 502-8:147
Litigation
Complaint
Ohio

Form 8:147 Complaint in Libel Per Se—General Form

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of action) No.
......................
Complaint

1. At all times mentioned, the defendant was and still is the owner and publisher of a certain newspaper published
in the City of ...................... and of a general circulation in (area) known as .......................

2. On ...................... (date), the defendant published in the newspaper concerning plaintiff the following matter:
(insert matter exactly as it is printed in the article, headlines and all where these are essential to show the libel. It is
ordinarily not necessary, however, to insert more than the actual libelous portion of the article or so much more as
is needed to explain the libelous portion).

3. The matter so published concerning the plaintiff is false and defamatory.

4. At the time of such publication, the defendant knew or could with the exercise of reasonable care have
ascertained that the matter was untrue. (This does not seem to be an essential allegation, but is frequently
inserted).

5. By reason of such Publication, plaintiff was injured in his credit and reputation and suffered great pain and mental
anguish to his damage in the sum of $......................

WHEREFORE, plaintiff demands judgement in the amount of $......................, and costs.

By ............................................

(Signature, address, and

registration number of
attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document
 LexisNexis(R) Forms FORM 502-8:148
Litigation
Complaint
Ohio

Form 8:148 Complaint in Libel Per Se—Another Form

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

1. Plaintiff, since ...................... (date), and at all times material, was Mayor of the City of ......................

2. Defendant, on ...................... (date), maliciously and wilfully, with intent to injure plaintiff, published in
...................... Times, a newspaper published in ......................, Ohio and circulated in ......................, the following
false and defamatory article concerning plaintiff: (copy of article).

3. At the time of the publication defendant knew the article to be false.

4. After a request by plaintiff for a retraction and clarification, defendant, on ...................... (date), maliciously and
wilfully, with intent to injure plaintiff, also published in ...................... Times, the following false and defamatory
article concerning plaintiff: (copy article).

5. At the time of the publication of this article defendant knew it to be false.

6. By reason of such publications, plaintiff was injured in his reputation and suffered pain and mental anguish to his
damage in the sum of $.......................

WHEREFORE, plaintiff demands judgment against the defendant in the sum of $...................... and costs.

(Signature, address, and registration number or attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document
 LexisNexis(R) Forms FORM 502-8:149
Litigation
Complaint
Ohio

Form 8:149 Complaint for Libel Per Quod

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

1. At all the times mentioned, the defendant was and still is the owner and publisher of a certain newspaper known
as (set forth name) published in the City of ...................... and of general circulation in (state area).

2. On ...................... (date), the defendant published in the newspaper concerning the plaintiff the following matter:
(set forth matter alleged to be libelous).

3. The matter so published concerning the plaintiff is false and defamatory.

4. At the time of such publication, defendant knew or could have ascertained with the exercise of reasonable care
that the matter was untrue.

5. Prior to the publication of the libelous matter concerning the plaintiff, he was about to enter into an agreement
with ...................... whereby ...................... was to employ plaintiff and would have employed him as ......................
at a salary of $...................... per month to commence on ...................... (date), had not the libelous matter been
published concerning the plaintiff, but, as a result of such publication, ...................... refused to employ plaintiff, and
up to the present time plaintiff has been unable to obtain employment and has otherwise been injured in his credit
and reputation, all to his damage in the sum of $.......................

(or)

5. At the time the libel was published concerning the plaintiff, and for ...................... months prior, plaintiff has been
employed by ...................... as ...................... at a salary of $...................... per month. Plaintiff had always
performed his services with ...................... in a satisfactory manner and would have been able to retain such
employment indefinitely had not the libelous matter been published concerning him. As a result of the publication of
such false and defamatory statement, plaintiff was discharged by ...................... and up to the present time has
been unable to obtain other employment and has otherwise been injured in his credit and reputation, to his damage
in the sum of $.......................

(or)

5. At the time the libelous matter was published concerning the plaintiff, he was engaged in conducting the business
of ...................... at No. ...................... Street in the City of ....................... By reason of such publication, a large
number of persons who had previously traded with plaintiff including (set forth names of as many persons as
possible who are no longer trading with plaintiff) thereafter refused and still refuse and fail to deal with plaintiff. Such
persons had been accustomed to purchase from plaintiff considerable quantities of goods of which purchases
 LexisNexis(R) Forms FORM 502-8:149

plaintiff has been deprived. As a result of such persons refusing and failing to trade with plaintiff, he has been
deprived of their trade and of substantial profits that he would have received from it, and there has been a general
decline in the amount of business done by him and in the profits received by him as a result of the publication of
such false and defamatory matter, and he has otherwise been greatly injured in his credit and reputation, all to his
damage in the sum of $.......................

(or)

5. By reason of the publication of such false and defamatory matter concerning plaintiff, various firms, persons, and
corporations with whom plaintiff had previously been doing business on credit and who had previously sold goods
to plaintiff on credit, to wit (insert names of those thereafter refusing credit) thereafter refused to sell goods to
plaintiff on credit and refused to deliver such goods to him unless he paid for them in cash at the time of such
delivery, and plaintiff was otherwise greatly injured in his credit and reputation, to his damage in the sum of
$.......................

WHEREFORE, plaintiff demands judgment against defendant in the amount of $......................, interest, and costs.

(Signature, address, and registration number of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8:150
Litigation
Complaint
Ohio

Form 8:150 Complaint in Libel Per Se Charging Actual Malice

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

1. At all the times mentioned, the defendant was and still is the owner and publisher of a certain newspaper known
as (set forth name) published in the City of ...................... and of general circulation (describe area).

2. On ...................... (date), the defendant published in the newspaper concerning the plaintiff the following matter:
(set forth as published).

3. The matter so published is false and defamatory.

4. At the time of such publication, the defendant knew or could have ascertained with the exercise of reasonable
care that the matter was untrue, and, in publishing such false and defamatory matter, defendant was actuated by
actual malice and wrongfully and willfully intended by such publication to injure plaintiff.

5. By reason of such publication, plaintiff was injured in his credit and reputation and suffered great pain and mental
anguish, all to his damage in the sum of $.......................

WHEREFORE, plaintiff demands judgment against defendant in the sum of $......................, including punitive
damages and attorney fees, and for interest, and costs.

(Signature, address, and registration number of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document
 LexisNexis(R) Forms FORM 502-8:151
Litigation
Complaint
Ohio

Form 8:151 Complaint in Libel Per Se for Publication Which May Be

Qualifiedly Privileged

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

1. Prior to ...................... (date), plaintiff was in the employ of the defendant as his secretary and left such employ on
...................... (date).

2. Thereafter, and on ...................... (date), plaintiff applied for a position as secretary to one ......................, residing
at No. ...................... Street in the City of ......................, County of ......................, and State of Ohio and, among
others, gave the name of defendant as a reference.

3. Thereafter, and on ...................... (date), the defendant maliciously composed and published concerning the
plaintiff, in a letter written to ...................... in answer to an inquiry made concerning plaintiff, the following false and
defamatory matter:
“Replying to your letter of recent date concerning ...................... (meaning this plaintiff) I would say that I cannot
recommend him to you. I was forced to discharge him from his employment with me for the reason that I found him
to be dishonest and unreliable.”

4. The matter so published of and concerning plaintiff is false and defamatory.

5. At the time of such publication, defendant knew that the matter was false and defamatory, and the statements
were made by him with actual malice and with the willful intent to injure and damage plaintiff in his reputation and
good name and to prevent him from obtaining employment.

6. By reason of the publication, plaintiff was refused employment by ...................... and was otherwise injured in his
credit and reputation and suffered great pain and mental anguish, to his damage in the sum of $......................

WHEREFORE, plaintiff demands judgment against defendant in the amount of $......................, interest, and costs.

(Signature, office and P.O. address of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.
 LexisNexis(R) Forms FORM 502-8:151

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8:154
Litigation
Complaint
Ohio

Form 8:154 Complaint in Libel Per Se for Publication Injuring Professional

Reputation

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

1. The defendant, at all the times mentioned, had and still has its office and principal place of business in the City of
......................, ...................... County, Ohio; and at such times it owned and there published a daily morning
newspaper known as the “...................... Daily Press,” which was widely circulated and read throughout the State of
Ohio and the country at large.

2. The plaintiff, at all the times mentioned was, for thirty years prior thereto, had been, and now is an architect,
highly trained in such profession by a long period of study, and extensive practical experience; and actually
engaged in the practice of his profession as such architect at ......................, Ohio, and elsewhere.

3. On ...................... (date), and for fifteen years before that date, plaintiff was a member in good standing of the
American Institute of Architects, an organization requiring its members to maintain the highest standards of
professional character, reputation, and efficiency; and in his profession as an architect enjoyed an extensive and
lucratice practice extending throughout the State of Ohio and elsewhere, devoted particularly to designing and
supervising the construction of high-class and costly buildings; and at all times prior to that date had been of good
name, fame, and credit in his profession.

4. Prior to the month of ...................... 19 ............, plaintiff as such architect submitted to the proper authorities of
the ......................, plans and specifications for a new high school proposed to be erected in that city, which plans
and specifications were, in or about the month of ...................... 19............, accepted by the authorities. In
connection with the preparation of these plans and specifications, and in an effort to perfect the same so as to meet
the requirements of the highest type of modern school buildings, plaintiff devoted much time and expended large
sums of money in special investigation and personal inspection of structures of similar character throughout the
country.

5. During the period between the month of ...................... 19............, and ...................... 19............, plaintiff, as such
architect, was engaged in supervising the construction of the high school, which shortly prior to that date was
accepted by the school district; and ever since has been and now is continuously used for school purposes. The
high school, as so completed and accepted, conformed, and now conforms, in every detail of its design,
construction, and equipment to the highest standard of modern high school buildings, and then was and now is
conceded by experts in architecture and by the public in general to be in all respects as perfectly adapted to its
purposes as any building of like character in the State of Ohio or elsewhere.

6. On ...................... (date), the defendant falsely and maliciously composed and published upon the editorial page
of the ...................... Daily Press, issued on that day, an article referring to and concerning this plaintiff in his
 LexisNexis(R) Forms FORM 502-8:154

profession, in the following false and defamatory words, to wit: “...................... has a new $750,000 high school
which was first used when the fall term began. Yet 850 pupils of that same high school are in possible danger
because of conditions which have come to the attention of the school board. The roof is in danger of falling. One
portion of it has broken away from the I-beams and has sagged toward the floor. At present the roof is propped up,
but if it should fall it would be disastrous to life and property. The architect has been notified, but has ignored the
notification. An expert has been sent for and precautions have been taken. This development does not speak very
well for those who designed and built ......................’s new high school.”

7. The matter contained in the article as above set forth was and is wholly false and defamatory in its entire intent,
purport, and meaning. The person referred to in the article as “The architect,” and one of the persons therein
referred to as “those who designed and built ......................’s new high school,” is the plaintiff in this action. In the
article, the defendant meant, intended to, and did falsely and maliciously charge, and caused the readers of the
newspaper to believe, that the plaintiff had ignored the notification mentioned, for the reason that he had been, and
knew he had been, derelict in his duty as architect of the high school, and had not, and knew he had not, conformed
to the standards and requirements of his profession; that by ignoring the notification he had tacitly admitted that he
was guilty of such dereliction of duty; that his ignoring the communication in itself demonstrated that he had not
conducted himself in his profession in the manner in which its ethics required; and that by reason of such dereliction
of duty and failure to conform to the standards and ethics of his profession, he was professionally and morally unfit
to undertake other work of similar character, lacked professional integrity, and was wanting in those qualifications
which attract patronage and are essential to his calling.

8. By reason of the composing and publishing by the defendant of the false and defamatory matter and as a direct
consequence, the plaintiff has been irreparably injured in his profession and in his good name, fame, and credit; his
standing in his profession has been seriously impaired; his earning capacity injured; his professional reputation as a
designer of public school buildings has been destroyed; the likelihood that plans for similar structures hereafter
submitted by him will be accepted has been rendered negligible; he has been undermined in the confidence of the
community, which is the foundation of professional success; and has suffered great personal humiliation and mental
anguish, all to his damage in the sum of $.......................

WHEREFORE, plaintiff demands judgment against defendant in the amount of $......................, and costs.

(Signature, office, and P.O. address of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8:153
Litigation
Complaint
Ohio

Form 8:153 Complaint in Libel Where Extrinsic Facts Are Pleaded to

Establish Innuendo and That Publication Was Libelous

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

1. At all the times mentioned, the defendant was and still is the owner and publisher of a certain newspaper
published in the City of ...................... and of general circulation, known as .......................

2. On ...................... (date), the defendant published in the newspaper concerning plaintiff the following false and
defamatory matter:

“(Name of plaintiff) a dashing blonde, twenty years old and is said to have been a concert hall singer and dancer at
.......................”

3. As is well known in the City of ......................, the concert halls at ...................... in the city are places of evil
repute and resorts for disorderly and disreputable persons. Female singers and dancers there are generally
depraved and abandoned women or are so regarded and understood to be and as such are shunned and avoided
by orderly and reputable people.

4. By the article set forth, the defendant meant, intended to mean, and was understood to mean by the persons
reading the article that plaintiff was unchaste and had been an inmate of a resort for dissolute, unchaste, disorderly,
and disreputable persons.

5. The article so published concerning the plaintiff is false and defamatory.

6. At the time of such publication, the defendant knew or could with the exercise of reasonable care have
ascertained that the matter was untrue.

7. By reason of such publication, plaintiff was injured in reputation and her standing in the community and suffered
great pain and mental anguish, to her damage in the sum of $.......................

WHEREFORE, plaintiff demands judgment against defendant in the sum of $......................, and costs.

(Signature, office, and P.O. address of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

 LexisNexis(R) Forms FORM 502-8:153

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8:158
Litigation
Complaint
Ohio

Form 8:158 Complaint for Libel and Slander and Conspiracy to Defame—
Against Some John Doe Defendants

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CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

COUNT ONE

1. Defendant ...................... Newspapers, Inc., during the time mentioned, did, and still, publishes a newspaper
known as and called ...................... Star, which newspaper is widely circulated and read in the State of Ohio and in
other states of the United States, particularly in .......................

2. Defendant ...................... is the publisher of the ...................... Star.

3. Defendant ...................... is a columnist whose writings appear in the ...................... Star.

4. Defendant ...................... is a member of the Ohio bar and practices law in .......................

5. Second Doe and Third Doe are members of the ...................... bar, and may also be members and officers of the
American Bar, and whose names will be supplied as plaintiff becomes aware of their identity.

6. The names of defendants Second Doe and Third Doe are unknown to plaintiff at the present time, and plaintiff
will amend this complaint by substituting their true names and charging each of them respectively and according as
he may be advised.
 LexisNexis(R) Forms FORM 502-8:158

7. The names of defendants Black Corporation, White Corporation, and Yellow Corporation are unknown to plaintiff
at the present time, and plaintiff will amend this complaint by substituting their true names and charging each of
them respectively and accordingly as he may be advised.

8. Plaintiff is now a lawyer and has been such for some thirty years, is now a member of the ...................... State
Bar Association and various other bar associations, both local, federal, and national.

9. Plaintiff has for many years enjoyed an excellent reputation as a private citizen and as an attorney, admitted to
practice in the courts of the State of ...................... and in the Supreme Court of the United States.

10. Defendants ...................... Newspapers, Inc. ......................, and ......................, maliciously contriving and
intending to injure plaintiff and deprive him of the respect, confidence, and esteem peculiarly essential to plaintiff’s
profession and contriving and intending to deprive plaintiff of his good name, reputation, and the esteem of his
clients, and to bring him into disastrous scandal, ridicule, hatred, contempt, and professional disrepute with his
clients, professional associates, friends, and acquaintances, and the public in general, and to hold plaintiff up to
public scorn, contempt, ridicule, hatred, and disgrace, on ...................... (date), and ...................... (date), did, with
actual malice, falsely and wrongfully publish and circulate concerning plaintiff in the ...................... Star under title of
“......................” by ......................, defendant, and headed “......................,” the following malicious, false,
scandalous, and defamatory libel, which is attached as Exhibit A.

11. By reason of the malicious publication and dissemination of the information contained in the article by
defendant’s circulation of its newspaper, the plaintiff has been deprived in the State of Ohio of the public confidence
which he had as a private citizen, and as an attorney; has suffered embarrassment, humiliation, and mental agony;
and has been held in contempt, hatred, ridicule, calumny, and distrust.

12. On ...................... (date), plaintiff, pursuant to Ohio Revised Code Section 2739.13, caused to be delivered to
the offices of the defendants, ...................... Newspapers, Inc., and ......................, by certified mail, a notice and
demand for publication of a full and fair correction. A copy of the notice and the full and fair correction demanded to
be published are attached as Exhibit B.

13. On ...................... (date), defendant published its “Retraction, Correction and Apology to Mr. ......................,” a
copy of which is attached as Exhibit C. This retraction republished the prior libel of defendants, was not published
without omissions or additions, and furthermore was not joined in by the writer and published as a part of his
column, in the manner of the original publication of the libel, and therefore did not fulfill the requirements of Ohio
Revised Code Section 2739.14.

14. Furthermore, the purported retraction by defendant ...................... Newspapers, Inc. was not published in good
faith because defendants knew the article was willful, false, and malicious before they received the demand for
retraction, and defendants, nevertheless sat idly by and did nothing until plaintiff demanded a retraction.

COUNT TWO

15. Plaintiff realleges all the matters stated in Count One, in Paragraphs 1 through 14.

16. Defendant ...................... at all times mentioned has been and is now a member of the ...................... bar and a
practicing attorney in .......................

17. On or about ...................... (date), defendant ...................... maliciously and with intent to cause it to be believed
that this plaintiff was an unworthy and dishonest attorney and in order to injure the plaintiff and deprive him of the
respect, confidence, and esteem peculiarly essential to plaintiff’s profession, and contriving and intending to deprive
him of his good name, reputation, and the esteem of his clients, and to bring him into disastrous scandal, hatred,
ridicule, and disgrace, and professional disrepute with his clients, professional associates, friends, and the public in
general, and to hold plaintiff up to public scorn, contempt, hatred, ridicule, and disgrace, and for the express
purpose of having the matters set forth published and circulated by defendant ......................, Newspapers, Inc., did,

Page 2 of 3
 LexisNexis(R) Forms FORM 502-8:158

with actual malice, falsely and wrongfully, say and publish concerning plaintiff to defendant ...................... an
employee of the defendant-newspaper, the following malicious libelous, and defamatory slander: .......................

18. By reason of the malicious publication and dissemination of the false information stated in Paragraph 17,
plaintiff has been deprived in the State of Ohio of the public confidence which he had as a private citizen and as an
attorney; has suffered embarrassment, humiliation, and mental agony; and has been held in contempt, hatred,
calumny, distrust, disgrace, and ridicule.

19. Each of the statements of defendant ...................... were and are false and untrue and were made by such
defendant for the purpose of and pursuant to a preconceived policy and intent to injure plaintiff in his profession,
and the statements did injure plaintiff in his profession and in his personal standing and reputation.

20. Each of the false and untrue statements was, further, made by the defendant ......................, with the intention
and understanding that the defendant ...................... and the defendant-newspaper would give them wider
dissemination by newspaper in the manner subsequently published by defendant-newspaper.

COUNT THREE

21. For a claim against defendants ...................... Newspapers, Inc., ......................, ......................, ......................,
Black Corporation, White Corporation, Yellow Corporation, ......................, Second Doe, and Third Doe, plaintiff
realleges all the matters set forth in Count One, Paragraphs 1 through 14, and Count Two, Paragraphs 15 through
20.

22. Defendants ...................... Newspapers, Inc., ......................, and ......................, defendants Does, and
defendant-corporation named have participated and are participating in a long-standing conspiracy to abuse,
discredit, and vilify plaintiff because of his representation of individual clients and unpopular causes against Does
and Does’ corporate clients’ interests, and plaintiff’s lectures and writings, and suits against ......................
companies and teachings of demonstrative evidence to achieve awards in personal injury and damage suits and in
medical malpractice suits. The defendants Does belong to a small coterie of individuals, and Does, corporations are
devoted to perpetuating ancient and customary injustices and practices of law against seamen, railroad workers,
pedestrians, motorists, and those belonging to minority groups, and unpopular causes. The conspiracy is practiced
and continued by the defendants Does and defendant-corporations for the purpose of advancing their interests and
the interests solely of their clients and the institutions they represent.

23. As part of the continuing plans and conspiracy, and of the willful, malicious motives, defendants Does and
defendant-corporations, hereinafter to be named and charged, did cause to be published the shameful defamation
in the ...................... Star, as alleged in Paragraph 10.

24. By reason of the conspiracy alleged and its wide circulation in the State of Ohio and in the United States, and
among the people of such states, plaintiff has been injured in his good name, fame, and reputation, and in
pursuance of his profession as a practicing attorney, in his good standing and in his standing in the community, and
in the high regard, respect, confidence, and esteem he has hitherto enjoyed among his associates and among the
legal profession and elsewhere in the sum of $.......................

WHEREFORE, plaintiff demands judgment against the defendants for the sum of $...................... for compensatory
damages and for the sum of $...................... for punitive damages, for interest, and costs, and demands trial by jury.

(Signature, office, and P.O. address of attorney for plaintiff)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 3 of 3
 LexisNexis(R) Forms FORM 502-8:159
Litigation
Complaint
Ohio

Form 8:159 Complaint for Slander Per Se

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

1. On ...................... (date), at ......................, in the City of ...................... ......................, ......................, the

defendant in the presence and hearing of one ...................... and several other persons, whose names are unknown
to plaintiff, maliciously spoke concerning the plaintiff the following false and defamatory words: (Set forth alleged
defamatory words).

2. The words so spoken were false and defamatory.

3. By reason of such words having been spoken of and concerning the plaintiff, plaintiff was injured in his reputation
and has suffered great pain and mental anguish, to his damage in the sum of $.......................

Wherefore, plaintiff demands judgment against the defendant in the sum of $...................... and costs.

(Signature, office, and P.O. address of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document
 LexisNexis(R) Forms FORM 502-8:160
Litigation
Complaint
Ohio

Form 8:160 Complaint for Slander Per Quod

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

1. Heretofore and on ...................... (date), at ......................, the defendant in the presence and hearing of one
...................... and several other persons maliciously spoke concerning the plaintiff the following false and
defamatory words: (Set forth words spoken).

2. The words so spoken of plaintiff were false and defamatory.

3. Prior to the speaking of words concerning this plaintiff, he was about to enter into an agreement with one
......................, whereby ...................... was to employ plaintiff and would have employed him as ...................... at a
salary of $...................... per month to commence on ...................... (date), had not the false and defamatory words
been spoken concerning the plaintiff, but as result of the speaking of such words, ...................... refused to employ
plaintiff, and up to the present time plaintiff has been unable to obtain other employment and has otherwise been
injured in his credit and reputation, all to plaintiff’s damage in the sum of $.......................

(or)

3. At the time the false and defamatory words were spoken concerning the plaintiff, and for ...................... months
prior thereto, plaintiff had been employed by ...................... as ...................... at a salary of $...................... per
month. Plaintiff had always performed his services with ...................... in a satisfactory manner and would have
been able to retain such employment indefinitely had not the false and defamatory words been spoken concerning
him. As a result of the speaking of such false and defamatory words, plaintiff was discharged by ......................, and
up to the present time has been unable to obtain other employment and has otherwise been injured in his credit and
reputation, all to his damage in the sum of $.......................

(or)

3. At the time the false and defamatory words were spoken concerning plaintiff, he was engaged in conducting the
business of ...................... at ...................... in the City of ......................, County of ......................, and State of Ohio.
By reason of such speaking of such false and defamatory words, a large number of persons who had previously
traded with plaintiff, including (set forth names of as many persons as possible who no longer trade with plaintiff as
a result of the slander) thereafter refused and still refuse and fail to deal with plaintiff. Such persons had been
accustomed to purchase from plaintiff considerable quantities of goods of which purchases plaintiff has been
deprived. As a result of such persons refusing and failing to trade with plaintiff, he has been deprived of their trade
and of substantial profits which he would have received from it, and there has been a general decline and falling off
of the amount of business done by him and in the profits received by him as a result of the speaking of such false
 LexisNexis(R) Forms FORM 502-8:160

and defamatory words, and he has otherwise been greatly injured in his credit and reputation, to his damage in the
sum of $.......................

(or)

3. By reason of the speaking of such false and defamatory words of and concerning plaintiff, various firms, persons,
and corporations with whom plaintiff had previously been doing business on credit and who had previously sold
goods to plaintiff on credit, to wit: (insert names of those thereafter refusing credit), thereafter refused to sell goods
to plaintiff on credit and refused to deliver such goods to him unless he paid for them in cash at the time of such
delivery, and plaintiff was otherwise greatly injured in his credit and reputation, to his damage in the sum of
$......................

WHEREFORE, plaintiff demands judgment against defendant in the amount of $......................, interest, and costs.

WHEREFORE, plaintiff demands judgment against defendant in the amount of $......................, interest, and cost

(Signature, office, and P.O. address of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8:161
Litigation
Complaint
Ohio

Form 8:161 Complaint in Libel Per Se Where Extrinsic Facts Must Be

Pleaded to Explain Defamation

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

1. Heretofore and on ...................... (date), at ......................, in the presence of one ...................... and several other
persons, the defendant spoke concerning the plaintiff the following false and defamatory words: “You [meaning
plaintiff] took a long chance when you testified [referring to evidence given by the plaintiff in an action in the
...................... Court of ...................... County wherein ...................... was plaintiff and ......................, the plaintiff
above named, was defendant and in which plaintiff above named testified in his own behalf]. I wouldn’t have done
what you did for the whole amount that was involved, swear to a damned lie.” [Meaning that plaintiff had testified
falsely in the action.]

2. By such false statements, defendant intended to charge and did in fact charge and was understood by the
persons who heard the statements to charge that plaintiff above named had as a witness in the action mentioned
committed the crime of perjury in having willfully and knowingly given false testimony at the trial thereof.

3. The words so spoken were false and defamatory.

4. By reason of such false statement, plaintiff has been injured in his good name and reputation and has suffered
great pain and mental anguish, to his damage in the sum of $.......................

WHEREFORE, plaintiff demands judgment against defendant in the sum of $......................, and costs.

(Signature, office, and P.O. address of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document
 LexisNexis(R) Forms FORM 502-8:162
Litigation
Complaint
Ohio

Form 8:162 Complaint on Slander of Title of Real Property

Use lexis.com to investigate real property:

● Public Records > Smartlinx(TM) > Smartlinx Location Summary Report
◯ To search, simply choose a permissible use from the DPPA and GLBA drop downs, then enter the
property address. Location Summary Reports contain categories of descriptive information about
that site - including tax assessment, deed transfer, mortgage information, addresses, associates,
and other information. The reports are analytically generated from over 3,000 public records
sources.

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
action)
Complaint

1. At all times mentioned, the plaintiff was and still is the owner of certain lands and premises in the City of
......................, County of ......................, and State of Ohio, more particularly bounded and described as follows:
(Insert legal description).

2. Heretofore and on ...................... (date), the defendant, in the presence and hearing of one ...................... and
several other persons spoke concerning plaintiff and the plaintiff’s ownership of the real property described the
following false and defamatory words: “He [meaning this plaintiff] isn’t the owner of this property [meaning the
property described]. He [meaning this plaintiff] can’t give you good title to it. It [meaning the property described] is
really owned by ...................... and the deed which ...................... gave to him [meaning this plaintiff] is really a
mortgage.”

3. The words so spoken by the defendant were and are false and defamatory, and were known by the defendant to
be false and defamatory when spoken, and were spoken by the defendant willfully and maliciously and with intent to
injure the plaintiff and his title to the property.

4. At the time such words were so spoken, one ......................, who was among those to whom the words were
spoken, was ready, willing, and able to purchase the property and would have purchased the same and would have
paid to this plaintiff the sum of $...................... therefore and, as plaintiff has been informed and believes, others
who heard the words were also ready and willing to purchase the property and would have purchased the same
and would have paid plaintiff at least the sum of $....................... By reason of the words so spoken by the
defendant, plaintiff has been unable to sell the property for more than $......................, all to his damage in the sum
of $.......................
 LexisNexis(R) Forms FORM 502-8:162

WHEREFORE, plaintiff demands judgment against defendant in the amount of $......................, interest, and costs.

(Signature, office, and P.O. address of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8.174
Litigation
Complaint
Ohio

Form 8:174 Complaint for Malicious Prosecution—General Form

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
Action)
Complaint

1. Heretofore, and on ...................... (date), at ......................, the defendant maliciously and without probable cause
went before Hon. ......................, ......................, Judge of the ...................... (or other judge or magistrate), and
charged plaintiff before the judge with having committed the crime of grand larceny in having stolen from the
defendant the sum of $...................... and procured and caused a warrant to be issued by the judge (or magistrate)
for the arrest of plaintiff

2. Thereafter, and on ...................... (date), at ......................, plaintiff was arrested under the warrant and was taken
to the ...................... jail and was there imprisoned and detained for a period of ...................... days and then was
held in bail to answer to the charge at a hearing to be held before ...................... (or magistrate) in the sum of
$......................

3. Thereafter, and on ...................... (date), a hearing was held before ......................, judge (or magistrate) and
plaintiff was tried upon the charge by ...................... court and was then and there acquitted and discharged, and,
thereby, the prosecution was wholly terminated.

4. By reason of the arrest and malicious prosecution of the plaintiff by the defendant as alleged, plaintiff was
subjected to great indignity and humiliation, pain, and distress of mind and body, was prevented from attending to
his usual business, was subjected to expense in the sum of $...................... in the procurement and services of
counsel in his defense upon the charge, and was injured in his good name and reputation in the community, all to
his damage in the sum of $......................

WHEREFORE, plaintiff demands judgment against defendant in the sum of $...................... and costs.

(Signature, address, and registration number of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document
 LexisNexis(R) Forms FORM 502-8.175
Litigation
Complaint
Ohio

Form 8:175 Complaint for Malicious Prosecution Where Plaintiff Waived

Examination and Furnished Bail

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
Action)
Complaint

1. On ...................... (date), the defendant, without probable cause, and without having any just cause against
plaintiff, wrongfully, willfully, maliciously, and falsely, and with intent to injure the plaintiff, signed an affidavit before
Hon. ......................, Judge of the County Court of ...................... County, ...................... District, falsely charging
plaintiff with the crime of assault and battery under Ohio Revised Code Section 2901.25.

2. On this affidavit, Hon ......................, Judge, issued a warrant, and the warrant was delivered to ......................
(name and official capacity), and plaintiff was then arrested on such warrant at his residence at ...................... by
.......................

3. Plaintiff was then taken as prisoner from his place of residence on ...................... (date), and was publicly taken
before ...................... to be charged.

4. At the time and place where he was charged with such crime, plaintiff was not represented by counsel, and he
was advised to waive examination.

5. Plaintiff, on such advice, waived examination and was thereupon taken as a prisoner to the jail at ......................
and placed in such jail and kept in the company of criminals and undesirable persons for ...................... hours,
against the will of the plaintiff, until he was admitted to bail of $.......................

6. On being taken to the ...................... County jail and before being released from the jail, the sheriff of the county
and his deputies, against the will of this plaintiff, forced the plaintiff to be fingerprinted several times, and to answer
questions concerning his name, age, place of residence, and a complete description of the plaintiff for the purpose
of depositing and keeping same as part of the criminal records of the State of Ohio, on file and open to public
inspection at all times. Although plaintiff has been discharged and exonerated of the alleged crime, these
fingerprints and records have never been returned to him, are still a public record, and open at all times to
inspection by the public generally.

7. Thereafter, the charge against this plaintiff was investigated by the Grand Jury of the County of ......................
and on ...................... (date), and after investigating the charge, the grand jury failed to find an indictment and
dismissed the charge against this plaintiff, and an order of dismissal was granted on ...................... (date), this
terminating the proceeding in favor of the plaintiff.

8. In the proceeding before Hon. ......................, Judge of the County Court of ...................... County, ......................
District, the defendant falsely, wrongfully, and maliciously and with intent to injure the plaintiff, his good name, his
 LexisNexis(R) Forms FORM 502-8.175

reputation, his credit in business, and to bring him into public disgrace, and without probable cause or reason,
charged the plaintiff with the crime of assault and battery, and also, as the plaintiff is informed and believes, and
without probable cause, charged the plaintiff before the grand jury with the same crime.

9. The fact of plaintiff’s arrest and being held to await action of the grand jury was widely publicized in the
newspapers in ...................... and other places in the state, which reports caused the plaintiff mental anguish and
pain and injured him and his standing in the community and among his friends and neighbors, all of which was a
direct result of the action taken by the defendant in falsely causing plaintiff’s arrest.

10. The plaintiff is employed as a ...................... by ...................... and is required to ...................... (state nature of
duties that may be affected or responsibilities impaired by arrest, etc.), in the course of which he is required to meet
the public generally, and because of the action of the plaintiff and the false charges against him, he is constantly
humiliated in meeting the public in this work, having been branded as a criminal in his community and to the public
generally.

11. Because of the false charges and arrest instigated by the defendant, the plaintiff expended the sum of
$...................... as counsel fees to his attorney, ......................, to represent him and defend him on these charges.

12. The plaintiff was not guilty of assault and battery and, at the time of his arrest, was a good and worthy citizen
and respected by his neighbors, and the charge made by the defendant, and the arrest and imprisonment were
made and caused by the defendant without any probable cause to suspect the plaintiff of assault and battery or any
other crime, and the arrest and detention were malicious and unlawful.

13. By reason of the facts set forth, the plaintiff was injured and impaired in his credit, good name, and reputation,
and was prevented from tending to his work and employment and forced to suffer great bodily distress and mental
anguish, and was compelled to expend money and incur expenses for attorney and counsel fees in the proceeding
and incurred other expenses by reason of the facts hereinbefore set forth, all to his damage in the sum of
$.......................

WHEREFORE, plaintiff demands judgment against defendant in the amount of $...................... interest and costs.

(Signature, address, and registration number of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8.176
Litigation
Complaint
Ohio

Form 8:176 Complaint for Malicious Prosecution Based on Order of Arrest in

Civil Action

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
Action)
Complaint

1. On ...................... (date), the defendant commenced an action against the plaintiff in the ...................... Court of
...................... County, Ohio, and in the complaint in such action he alleged, among other things, that plaintiff had,
through false and fraudulent representations alleged to have been made by the plaintiff, defrauded defendant of the
sum of $......................, and demanded judgment against this plaintiff for that sum.

2. Thereafter and on ...................... (date), defendant maliciously and without probable cause applied to the
...................... Court for an order of arrest of plaintiff, falsely stating and alleging in an affidavit on which application
was made that this plaintiff fraudulently contracted the debt and incurred the obligation on which the claim in the
action was made, and by means of the false and fraudulent representations made in such affidavit, he caused and
procured the issuance of an order of arrest for plaintiff, ordering that plaintiff be arrested and confined in the custody
of the Sheriff of ...................... County, Ohio, until plaintiff had procured bail or until he was otherwise discharged
according to law.

3. The defendant thereupon willfully, maliciously, and without reasonable or probable cause therefor delivered the
order of arrest to the sheriff of the County of ...................... and instructed the sheriff to arrest plaintiff above named
thereunder and hold him in custody as thereby required.

4. Thereafter and on ...................... (date), purporting to act under the order of arrest, the Sheriff of the County of
...................... arrested plaintiff and took him in custody through the streets of the City of ...................... to the jail of
the County of ...................... and there confined and imprisoned him in custody for ...................... hours.

5. On ...................... (date), the order of arrest was vacated by an order of ...................... Court of ......................
County on the ground that the same had been improvidently, improperly, and illegally granted and issued, and
plaintiff was thereupon discharged from custody and arrest by the Sheriff of the County of ....................... The time
of the defendant to appeal from the order vacating the order of arrest has fully expired.

6. Thereafter, plaintiff duly appeared in the action and served an answer denying generally all of the allegations of
the complaint, and thereafter such proceedings were had in the matter that after a trial of the action a verdict was
rendered by the jury in the ...................... Court of ...................... County in favor of plaintiff and against defendant
dismissing the action brought against plaintiff, and thereby all proceedings against the plaintiff upon the action were
terminated.

7. By reason of the arrest and malicious prosecution of the plaintiff by the defendant, plaintiff was subjected to great
indignity, humiliation, pain, and distress of mind and body, was injured in his character and reputation, was
 LexisNexis(R) Forms FORM 502-8.176

prevented from attending to his usual business and vocation, was subjected to expense in the procurement of
counsel in his defense in the action and to procure his release from custody under the order of arrest, and was
injured in his good name and reputation in the community in which he lives, all to his damage in the sum of
$.......................

WHEREFORE, plaintiff demands judgment against defendant in the amount of $...................... and costs.

(Signature, office, and P.O. address of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8.173
Litigation
Complaint
Ohio

Form 8:173 Complaint for False Imprisonment Where Store Employees

Arrest and Search Person for Shoplifting

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
Action)
Complaint

1. At all the times mentioned, the defendant was and still is engaged in operating a department store at No.
...................... Street in the City of ......................, County of ......................, and State of Ohio.

2. On ...................... (date), at about ...................... o‘clock in the ...................... noon of that day, plaintiff was
lawfully in defendant’s store for the purpose of purchasing certain of the merchandise, and, while examining
merchandise prior to purchase, she was forcibly and violently seized and laid hold of by the superintendent and the
private detective of defendant, both of whom were the servants and agents of the defendant, employed as such by
him and acting under such employment and within the scope of their authority, and at the same time and place they
falsely, publicly, and maliciously accused the plaintiff of having stolen from the defendant (set forth goods alleged to
have been stolen).

3. Plaintiff did not steal ...................... or any other matter or thing from the defendant, and she then and there so
stated and demanded to be released.

4. The superintendent and the private detective, as such agents and servants of the defendant and acting in the
performance of such employment and within the scope of their authority, refused to release plaintiff but then and
there arrested plaintiff and threatened her with prosecution for the alleged theft of ...................... from defendant.

5. Thereupon, the superintendent and the private detective of defendant, as such agents and servants of the
defendant acting under their employment as such within the scope of their authority, again forcibly and violently
seized and assaulted and laid hold of plaintiff against her will and consent, placed her under arrest, and falsely and
maliciously detained and imprisoned the plaintiff and compelled her to submit to a search or examination of her
clothing and person at the hands of the private detective in the store of the defendant, for the alleged purpose of
discovering property claimed to have been stolen from defendant, without any reasonable or probable cause and
contrary to the laws of the State of Ohio.

6. By reason of the assault and the false and malicious arrest, detention, and imprisonment of the plaintiff, plaintiff
was subjected to great humiliation and disgrace in being so detained and imprisoned and was compelled to walk
the entire length of defendant’s store surrounded by a large crowd of Christmas shoppers and customers who were
made aware that plaintiff had been arrested and charged with being a thief, and, further, by reason of such
exposure, arrest, detention, imprisonment, and search of the plaintiff, she was injured in her credit and reputation
and was then and there hindered and prevented from performing her necessary transactions and business and was
caused to suffer pain and mental anguish, all to her damage in the sum of $.......................
 LexisNexis(R) Forms FORM 502-8.173

WHEREFORE, plaintiff demands judgment against defendant in the amount of $...................... and costs.

(Signature, office, and P.O. address of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8.177
Litigation
Complaint
Ohio

Form 8:177 Complaint for False Imprisonment, Malicious Prosecution, and

Assault

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
Action)
Complaint

1. At all times mentioned, defendant was, and still is, engaged in carrying passengers for hire on its bus lines, under
the care and management of certain of its servants and employees, on the public streets of the City of
......................, Ohio.

2. In the evening of ...................... (date), in the City of ......................, plaintiff paid the fare and became a
passenger in one of defendant’s buses operated on the line running from ...................... to .......................

3. Certain servants and employees of defendant were on such bus and were assisting in the control, management,
and operation of the bus.

4. In the evening of ...................... (date), when and as soon as the bus of defendant upon which plaintiff was riding
as a passenger had reached and stopped at the platform at ...................... Street and ...................... Avenue, in the
City of ......................, plaintiff attempted to alight from and leave the car and go upon the platform for the purpose of
proceeding to his home. While plaintiff was attempting to alight from and leave defendant’s bus upon which he was
riding as a passenger and go upon the platform of defendant, two of the servants and employees of defendant, who
were employed by defendant to assist in the control, management, and operation of defendant’s buses, and who
were then and there acting within the scope of their duty and authority from defendant and were assisting in the
control, management, and operation of the buses, with force and arms forcibly and violently seized, assaulted, and
laid hold of plaintiff and, at the same time and place, falsely, publicly, and maliciously accused plaintiff of the crime
of disorderly conduct tending to a breach of the peace.

5. Plaintiff did not, at the time and place or at any other time and place, conduct himself in a disorderly manner
tending to a breach of the peace, and plaintiff then and there so stated to the two servants and employees of
defendant, who had with force and arms forcibly and violently seized, assaulted, and laid hold of plaintiff as
aforesaid and who were restraining him of his liberty against his will, and plaintiff then and there demanded that the
two servants and employees of defendant release him from such restraint, but the two servants and employees of
defendant, acting within scope of their duty and authority from defendant, refused to release plaintiff from their
custody, but, on the contrary, the two servants and employees of defendant, acting within the scope of their duty
and authority from defendant, then and there did, without any probable or reasonable cause therefor, summon and
call a police officer of the City of ...................... and did again falsely, publicly, and maliciously accuse plaintiff of the
crime of disorderly conduct tending to a breach of the peace and did direct and cause the police officer to arrest and
take plaintiff to a police station, where plaintiff was locked up and confined in a cell, as a criminal.
 LexisNexis(R) Forms FORM 502-8.177

6. In the evening of ...................... (date), upon the platform of defendant at or about ...................... Street and
...................... Avenue, in the City of ......................, plaintiff was charged publicly with the crime of disorderly
conduct tending to a breach of the peace by the two servants and employees of defendant, acting within the scope
of their duty and authority from defendant, and in the presence of a number of citizens was arrested and restrained
of his liberty by the police officer of the City of ......................, and plaintiff was then and there forced and compelled
by the police officer to proceed in and along divers public streets of the City of ......................, to a police station of
the ...................... Precinct, situated at ...................... Avenue and ...................... Street, where plaintiff was, without
probable or reasonable cause therefor, publicly charged by the two servants and employees of defendant, acting
within the scope of their duty and authority from defendant, with the crime of disorderly conduct tending to a breach
of the peace, and was then and there restrained of his liberty and subjected to humiliation and disgrace as a
criminal and was confined and locked up in a cell as a criminal, in the police station.

7. Plaintiff remained under arrest and was confined and locked in a cell in the police station, without probable or
reasonable cause and against his will, from about ...................... m. in the evening of ...................... (date), until
about ...................... m. in the morning of ...................... (date); and at such later time, upon being brought before
Hon. ...................... to be charged with the crime of disorderly conduct tending to a breach of the peace, he was
thereupon compelled to give bail in the amount of $...................... for his appearance before Hon. ...................... on
...................... (date).

8. One of the servants and employees of defendant, acting within the scope of his duty and authority, from
defendant, on or about ...................... (date), went before the Hon. ...................... and made, signed, and verified a
complaint in writing charging plaintiff with the crime of disorderly conduct tending to a breach of the peace and
alleging that the crime was committed on the bus platform of defendant at ...................... Street and ......................
Avenue, in the City of .......................

9. On ...................... (date), plaintiff, upon an examination, was brought before Hon. ...................... and arraigned,
was then and there charged with the crime, pleaded not guilty, and was compelled to and did give bail in the sum of
$...................... for his appearance on the charge, and hearing upon the charge was adjourned to ......................
(date).

10. Thereafter, and on ...................... (date), a hearing was had on the charge and an examination made thereunder
before Hon. .......................

11. On ...................... (date), such proceedings were had before Hon. ...................... Plaintiff, having been arraigned
to answer the charge and having pleaded not guilty thereto, was duly tried, was found not guilty of the charge by the
magistrate, and was thereupon duly acquitted thereof and honorably discharged from arrest, and thereby the
complaint, charge, and prosecution were dismissed and the same were finally terminated and ended in favor of
plaintiff, and the charge has not been further prosecuted, but was and is thereby wholly terminated.

12. The prosecution, arrest, detention, and trial of plaintiff were instigated, procured, and set on foot by defendant,
acting by its servants and employees, in this action unlawfully, maliciously, without any reasonable or probable
cause whatsoever therefor.

13. Plaintiff, previous to his illegal arrest and imprisonment as aforesaid, bore a good reputation in the community in
which he resided, enjoyed the friendship of a large circle of friends, and was never before charged with or arrested
for any crime whatever.

14. Plaintiff was wholly innocent of the crime with which he was charged. By reason of the assault and the false,
illegal, and malicious arrest, detention, imprisonment, and trial occasioned by defendant, acting by its servants and
employees who were acting within the scope of their duty and authority from defendant and with the knowledge and
consent of defendant, plaintiff suffered great embarrassment, mortification, mental anguish, and physical
discomforts; was subjected to great humiliation and disgrace in being so falsely and illegally detained and
imprisoned and in being compelled to walk to the police station, and in being confined and locked up in a cell, as a
common criminal, in the police station, was greatly injured in his credit and circumstances; was then and there

Page 2 of 3
 LexisNexis(R) Forms FORM 502-8.177

hindered and prevented from performing and transacting his necessary affairs and business; and was compelled to
and did pay out and expend certain sums of money for fees to his attorney in defense of the charge and did lose
sums by reason of his inability to attend to his business, and did therefor expend the amount of $...................... in
such defense, and was further damaged in the amount of $...................... by reason of the acts of defendant.

WHEREFORE, plaintiff demands judgment against defendant in the amount of $......................, interest, and costs.

(Signature, address, and registraiton number of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 3 of 3
 LexisNexis(R) Forms FORM 502-8.177A
Litigation
Complaint
Ohio

Form 8:177A Complaint for Abuse of Process and Malicious Civil

Prosecution

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
Action)
Complaint

COUNT I

ABUSE OF PROCESS

1. At all times mentioned, plaintiff was, and still is, an attorney engaged in private practice in ...................... County,
Ohio.

2. At all times mentioned, defendant was, and still is, an attorney engaged in private practice in ......................
County, Ohio.

3. On ...................... (date), defendant filed a lawsuit against plaintiff alleging that plaintiff had improperly induced
defendant’s client to terminate her contractual and business relationship with defendant and enter a contractual and
business relationship with plaintiff, and claiming interference with business relations, conspiracy, and fraud and a
loss of legal fees due to the alleged fraud.

4. On ...................... (date), defendant voluntarily dismissed the fraud claim against the plaintiff.

5. On ...................... (date), the Court of Common Pleas of ...................... County, Ohio, granted plaintiff’s motion for
summary judgment on the allegations of interference with business relationship and conspiracy.

6. The defendant prosecuted the aforesaid civil action for an ulterior purpose or purposes, those purposes being to
induce the plaintiff’s client to discharge him as her attorney, to damage the plaintiff’s reputation, and to increase the
settlement value of the defendant’s claims.

7. The defendant’s actions constitute the tort of abuse of process.

8. As a result of the defendant’s abuse of process, the plaintiff has suffered damage to his reputation and his
livelihood.

COUNT II

MALICIOUS CIVIL PROSECUTION

1. Plaintiff repeats the allegations contained in Count I, Paragraphs 1 through 3, inclusive.

 LexisNexis(R) Forms FORM 502-8.177A

2. The defendant maliciously instituted the aforesaid civil action against the plaintiff.

3. The defendant lacked probable cause for the filing of the aforesaid civil action.

4. On ...................... (date), defendant voluntarily dismissed the fraud claim against the plaintiff.

5. On ...................... (date), the Court of Common Pleas of ...................... County, Ohio, granted plaintiff’s motion for
summary judgment on the allegations of interference with business relationship and conspiracy.

6. The defendant’s actions constitute the tort of malicious civil prosecution.

7. As a result of the defendant’s malicious civil prosecution, the plaintiff has suffered damage to his reputation and
his livelihood.

WHEREFORE, the plaintiff prays judgment against the defendant in the amount of $......................, interest, and
costs.

(Signature, address, and registration number of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8.178
Litigation
Complaint
Ohio

Form 8:178 Complaint for Personal Injuries Under Federal Employers’

Liability Act

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
Action)
Complaint

COUNT I

1. Defendant ABC Railroad Co. is an ...................... corporation and is engaged in owning and operating a system
of railroads.

2. In the course of its business, defendant ABC Railroad Co. operates its trains over tracks at the ......................
Plant of the XYZ Company, at .......................

3. Defendant ABC Railroad Co. is engaged in interstate commerce by rail.

4. At all times mentioned, the plaintiff, HW, was an employee of ABC Railroad Co. and was engaged in activities
which directly, closely, and substantially affected interstate commerce by rail, and accordingly the rights, liabilities,
and duties as between plaintiff and defendant ABC Railroad Co. were governed by the federal statutes known as
the Federal Employers’ Liability Act.

5. Defendant XYZ Company is an ...................... corporation and is engaged in manufacturing steel and steel
products, and in the course of its manufacturing process operates a plant known as the ...................... Plant, at
......................, on which the defendant ABC Railroad Co. operates its trains.

6. Plaintiff, HW, is a frequenter at such ...................... Plant of defendant XYZ Company, his presence on the
property of XYZ Company being associated with the performance of his duties as an employee of ABC Railroad Co.

7. In the early morning hours of ...................... (date), plaintiff, HW, was engaged in his duties as a railroad worker
on the property of XYZ Company, and specifically in the area known as the ...................... Yard. At this time and
place, while plaintiff was engaged in the performance of his duties, the plaintiff was crushed between two cars and
suffered a mangling injury to his left leg, necessitating an amputation above the knee.

8. The injuries and damages suffered by plaintiff were directly and proximately caused by the negligence of
defendant XYZ Company in the operation of its overhead cranes while railroad workers were on its property, when
its crane operators knew or in the exercise of ordinary care should have known, of the presence of such workers; in
causing a derailment of cars so as to crush the plaintiff; and in the construction and maintenance of the track area
in a highly dangerous and unsafe condition.
 LexisNexis(R) Forms FORM 502-8.178

9. The defendant, ABC Railroad Co., was likewise careless and negligent in the construction and maintenance of
the track area upon which it required its employees to perform work.

10. The defendants, XYZ Company and ABC Railroad Co., failed to provide for safe methods of performing the
work which plaintiff was required to perform on the railroad cars; failed to have proper warning signals or signs,
adequate lighting, and reasonable rules for the performance of work in the area; and failed to provide the plaintiff
with a reasonably safe place to work.

11. Plaintiff, HW, was caused to suffer, as a direct and proximate result of the carelessness and negligence of the
defendants, from the date of this injury, great physical pain and suffering, mental pain and anguish, and total
disability. Plaintiff has, as a result, been unable to function as a normal, whole man. It is reasonably certain that
these conditions will continue until the trial of this action.

12. Plaintiff will, until his death, suffer continuing great physical pain and suffering, mental pain and anguish by
reason of such injuries.

13. Plaintiff will be disabled, and his ability to lead a normal life has been substantially destroyed for the remainder
of his life.

14. Plaintiff has lost income by reason of the impairment of his earning capacity since the date of his injury. It is
reasonably certain that he will suffer further impairment of his earning capacity for the remainder of his life.
Plaintiff’s ability to be rehabilitated and to return to the working force has been substantially destroyed.

15. Plaintiff has been required to obtain extensive medical, hospital, surgical, and prosthetic care and attention, and
to expend large sums of money for such care. It is reasonably certain that plaintiff will be required to expend
additional sums for such care for the remainder of his life. C OUNT II

16. Plaintiff, WW, incorporates all the allegations contained in Paragraphs 1 through 15 as if they were fully
restated.

17. Plaintiff, WW, is the wife of the plaintiff HW.

18. By reason of the carelessness and negligence of the defendants she has been deprived of the love, services,
aid, society, and consortium of her husband. The injuries suffered by her husband are permanent, and she will, for
the remainder of her husband’s life, be deprived of his services and consortium.

WHEREFORE, plaintiff HW, demands judgment against defendants, on the first cause of action, in the amount of
$......................, interest, and costs;

WHEREFORE, plaintiff, WW, demands judgment against defendants, on the second cause of action, in the amount of
$......................, interest, and costs;

WHEREFORE, plaintiffs, HW and WW, demand judgment against defendants on both causes of action, jointly and
severally, in the total amount of $......................, interest, and costs.

(Signature, office, and P.O. address of attorney for plaintiffs)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8.179
Litigation
Complaint
Ohio

Form 8:179 Complaint for Death of Employee Under Federal Employers’

Liability Act

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
Action)
Complaint

1. This action arises under the Federal Employers’ Liability Act.

2. Plaintiff is the administratrix of the Estate of AH, deceased, having been appointed as such on ......................
(date), by the Probate Division, Court of Common Pleas, ...................... County, Ohio.

3. Defendant, ...................... Steel Corp., is an Ohio corporation.

4. Defendant ...................... Railroad Co., is, and all times mentioned was, a railroad company, engaged in
interstate commerce as a common carrier, owning land and railroad equipment and performing the usual functions
of a railroad in the vicinity of ......................, Ohio.

5. AH, decedent-husband of plaintiff, was employed by defendant, ...................... Railroad Co., as a brakeman or
trainman, and both plaintiff’s decedent-husband and defendants were then engaged in interstate commerce and in
the furtherance of interstate commerce.

6. AH was performing his duties as brakeman or trainman, at ......................, Ohio on ...................... (date), and in
the performance of such duties was required to go on the premises of ...................... Steel Corp., with other
members of a crew to perform switching operations on railroad tracks located on property of ...................... Steel
Corp.

7. At approximately ...................... M. of that day, AH was crushed and killed by a railroad car when the train on
which the crew was working was derailed, because of the defective equipment with which the crew was permitted to
work and because of other negligence of defendants.

8. The injuries and death of plaintiff’s decedent were the direct and proximate result of the negligence of
...................... Steel Corp. and ...................... Railroad Co.

9. Each of the defendants, acting through their agents, servants, and employees, and while such agents, servants,
and employees were within the course and scope of their employment and under supervision of the defendants,
was negligent in certain respects, and such acts of negligence were the direct and proximate cause of the injuries
and death to plaintiff’s decedent. These acts involved, among others, maintaining and permitting to be maintained a
defective switch and switchpoint; requiring plaintiff’s decedent to work in a poorly and improperly maintained and
lighted area; failing to warn plaintiff’s decedent of the unsafe condition at the defective switchpoint; and in permitting
debris to accumulate in the area.
 LexisNexis(R) Forms FORM 502-8.179

10. Plaintiff’s decedent husband, AH, at the time of his death left surviving him the plaintiff, his wife, and
...................... children [or otherwise allege next of kin, relationship, and age, or other matters on which damages
are based].

11. Plaintiff’s decedent was ...................... years of age at the time of his death, and before the accident causing his
death he was of good character and health and capable of earning a substantial income.

12. The minor children of AH and plaintiff have been deprived of their probable inheritance from their deceased
father and have suffered pecuniary loss.

13. The minor children of AH and the plaintiff have been deprived of the advice, care, and counsel of their father
and husband, respectively, as a result of the death of AH.

14. The minor children of AH and the plaintiff have been damaged in the sum of $.......................

WHEREFORE, plaintiff demands judgment against defendants jointly and severally in the sum of $......................,
interest, and costs.

(Signature, office, and P.O. address of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2
 LexisNexis(R) Forms FORM 502-8.180
Litigation
Complaint
Ohio

Form 8:180 Complaint for Injuries Under FELA and Safety Appliance Act

CIVIL RULE 8(A)

COURT OF COMMON PLEAS, ...................... COUNTY, OHIO

(Title of No. ......................
Action)
Complaint

1. At all times and at the place mentioned, the defendant owned and operated a railroad in interstate commerce,
and plaintiff was employed by defendant in such commerce.

2. On ...................... (date), plaintiff was employed by the defendant as a conductor and was working in defendant’s
yard at ......................, Ohio, when, due to the negligence of the defendant, its agents, servants, and employees, he
was thrown from the top of a freight car and sustained severe, painful, and permanent injuries.

3. At the time and place mentioned, the agents, servants, or employees of defendant who were responsible for the
injury to the plaintiff were acting in the scope and course of their employment with, and under the direct and
exclusive control of, the defendant ...................... Company.

4. The negligence of the defendant by its agents, servants, and employees consisted of the following:
(a) Failure to give notice or warning to the plaintiff of the intention to move the train.
(b) The fellow employees carelessly, recklessly, and negligently operated the train in a shifting manner without
warning or notice to the plaintiff, and without due regard for the point and position in which he was then working,
and without due respect for the work he was then performing, as a result of which the movement made by the fellow
employees was negligent, careless, and the cause of this accident.
(c) Violating the rules of the company in regard to the operation of such trains under the circumstances, the same
being Rule 30 and other rules unknown to the plaintiff by number, as pertain to the shifting, stopping, and moving of
trains with the required signals and notice.
(d) Failure to ring the bell or whistle before operating the engine or train.
(e) Failure to provide the plaintiff with a safe place to work.
(f) Violating the standards prescribed by the Interstate Commerce Commission under the circumstances then and
there attendant, the same being in regard to equipment and movement of trains.
(g) The fellow employees were negligent in that they did move the train without knowing the whereabouts of the
plaintiff.
(h) The fellow employees were further negligent in moving the train without first obtaining the permission of the
plaintiff, who was their superior.
(i) The defendant was further negligent in that it supplied a defective brake on the freight car in question.

5. Defendant was further negligent in that it did violate the Safety Appliance Act pertaining to safety couplings and
brakes, in that the couplings and brakes were defective.
 LexisNexis(R) Forms FORM 502-8.180

6. As a result of the accident, the plaintiff suffered severe injury to his back, his hands and fingers, concussion of
the brain, with injury to its nerves, cells, tissues, and functions, and severe and permanent injury to his nerves and
nervous system.

7. Prior to these injuries, plaintiff was a strong, able-bodied man, capable of earning and actually earning
$...................... per day. By these injuries, he has been made incapable of any gainful activity, and has suffered
great physical and mental pain, and has incurred expenses in the amount of $...................... for medicine, medical
attention, and hospitalization.

WHEREFORE, plaintiff demands judgment against the defendant, ...................... Company, in the sum of
$......................, interest, and costs.

(Signature, address, and registration number of attorney for plaintiff)

(Demand for jury trial)

(Request for type of service)

Ohio Forms of Pleading and Practice

Copyright 2022, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

End of Document

Page 2 of 2