Form 15. Complaint for Damages Under Merchant Marine Act

1. Allegation of jurisdiction. [If the pleader wishes to invoke the distinctively maritime procedures referred to in Rule 9(h), add the following or its substantial equivalent: This is an admiralty or maritime claim within the meaning of Rule 9(h).]

2. During all the times herein mentioned defendant was the owner of the steamship ______ and used it in the transportation of freight for hire by water in interstate and foreign commerce.

3. During the first part of (month and year) at ______ plaintiff entered the employ of defendant as an able seaman on said steamship under seamen's articles of customary form for a voyage from ______ ports to the Orient and return at a wage of ______ dollars per month and found, which is equal to a wage of ______ dollars per month as a shore worker.

4. On June 1, 1936, said steamship was about ______ days out of the port of ______ and was being navigated by the master and crew on the return voyage to ______ ports. (Here describe weather conditions and the condition of the ship and state as in an ordinary complaint for personal injuries the negligent conduct of defendant.)

5. By reason of defendant's negligence in thus (brief statement of defendant's negligent conduct) and the unseaworthiness of said steamship, plaintiff was (here describe plaintiff's injuries).

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

Wherefore plaintiff demands judgment against defendant in the sum of ______ dollars and costs.

(As amended Feb. 28, 1966, eff. July 1, 1966.)

Notes of Advisory Committee on Rules-1966 Amendment

See Advisory Committee's Note to Form 2.