Draft A Complaint

Draft a Complaint with all appropriate allegations, and all applicable causes of action (there

clearly is more than one cause of action that should be pled), and in the correct format as

was taught in class. Also, include all appropriate Defendants.

FACT PATTERN:

Your client, Jose Rodriguez, purchased a used Porsche for

$40,000.00 from his good friend Bill Tobacco, who works as a car

salesman at the EyeGotU Car Dealership.

When leaving, Bill told Jose he has a side business selling electric

cigars, and convinced Jose to buy one at the cost of $5,000.00.

When walking out of the car dealership, Jose was fascinated by the

cigar and slipped and fell in some liquid on the floor severely

injuring his back, hip, and elbow. Later that night Jose was trying

to relax, and decided to try out his electric cigar when it blew up in

his face causing severe burns.

Making matters worse, because Jose couldn’t drive his car home

(following the slip and fall) the car was delivered to his home a

month later, at which time Jose learned that his “Porsche” has a

Volkswagen engine.

Jose wants to sue for any and all claims. Prepare the client

questionnaire.

Attorney Names

Attorneys’ Business Address

City, ST ZIP Code

Phone | Fax

Email

District court of appeal

Miami-Dade County, Florida

jONES, Plaintiff, vs. Smith, and   abc rEAlty corp., Defendant

Case No.: 123-45-6789 COMPLAINT

 

Plaintiff, Jones (“Jones”) hereby sues Defendants ABC Realty Corp. (‘ABC”) and Smith (“Smith”) and in support thereof, alleges as follows:

introduction

1.

Dated this day of Month, year.

Attorney Name

 

 

 

COMPLAINT – 1