Step One: Insert initial boilerplate language
First Paragraph: NOW COMES the Plaintiff, by and through her attorneys, Dewey Fuckem & Howe, with her complaint against the Defendant and complains as follows:Step Two: Find a plaintiff, defendant and jurisdiction and write your first two paragraphs
1. At all relevant times, the Plaintiff Jane Doe-Smith, was a resident of the State of Illinois. (Hereafter the “Plaintiff”)Step Three: Find something ominous that happened to the Plaintiff. Add legalese on a greased cookie sheet. Bake at 350 for 18 minutes. Cool before serving:
2. At all relevant times, the Defendant Big Evil Corporation with Insurance (Hereafter sometimes referred to as the “Hapless Money Bags that’ll pay my 1/3rd Contingency Fee” or “Defendant”) was a business entity doing business in the State of Illinois.
3. At all relevant times, the Defendant owned and operated a business in Chicago, Illinois. (Hereafter the “place where Plaintiff was a klutz” or the “premises”)
4. On or about January 15, 2010, Defendant Big Evil Corporation with Insurance had a dooty to exercise ordinary care in the operation, maintenance and upkeep of the premises so that it would be reasonably safe for persons lawfully on it, such as the Plaintiff.Step Four: What did your client slip on? If you don’t know, be vague. If do know, be vague.
5. On or about January 15, 2010, Plaintiff was lawfully on the premises.
6. On or about January 15, 2010, there was an unnatural accumulation of a foreign substance on the premises in and around the area where the Plaintiff was walking.
Step Five: Blame the employees for not fixing the problem. But do so that you can keep your law license if you find out your client is full of it.
7. Upon information and believe, the Defendant Big Evil Corporation’s Minions (hereafter referred to as “employees or agents”) attempted to clear the unnatural accumulation of a foreign substance from the area where the Plaintiff was walking.Step Six: It’s time to talk about a breach of dooty. The more dooty breached, the better.
8. On or about January 15, 2010, Defendant’s employees or agents failed to remove the unnatural accumulation of a foreign substance from the areas where the Plaintiff was walking.
9. Defendant’s employees and agents, knew or should have known that there was an unnatural accumulation of a foreign substance in around the area where the Plaintiff was walking.
10. On or about January 15, 2010, while the Plaintiff was lawfully on the premises, she became a klutz and slipped and fell because of an unnatural accumulation of a foreign substance.
11. On or about January 15, 2010, the Defendant breached its dooties and was negligent in one or more of the following ways:Step Seven: Them fucking up means lawyerman gets paaaaaaiiiiiid. Also known as the direct and proximate link.
a. Carelessly and negligently allowed the Plaintiff to do a triple axle, double loop in aisle nine;
b. Carelessly and negligently allowed its insurance company to hire a hack claims adjustor;
c. Carelessly, negligently and inexplicably allowed the Plaintiff to have her ambulance chased by counsel;
d. Failed to buy enough roombas to clean its floors and walkways;
e. Failed to hire the Janitor from Scrubs; and
f. Defendant was otherwise careless, negligent and/or fucked some shit up.
12. As a direct and proximate result of one or more of the aforesaid careless and negligent acts and /or omissions on the part of the Defendant and its agents and employees, a portion of the said premises, sidewalks and walkway areas were left in a dangerous condition upon which the Plaintiff slipped and fell causing severe and permanent injuries to herself.Step Eight: Insert the final boiler plate and ask for a shitton of money.
WHEREFORE, the Plaintiff, respectfully prays that this Honorable Court grant a judgment in her favor and against the Defendant in an amount in excess of $50,000,000, attorneys fees and costs as well as any additional relief that this Court deem proper and just.Step Nine: Sign, Copy and File.
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