Académique Documents
Professionnel Documents
Culture Documents
5
) Case No.: 123456-123
6 Joe Smith, )
)
7 Plaintiff, )
) MOTION TO DISMISS
8 vs. )
)
9 ABC Plumbing, Inc, )
)
10 Defendant )
11
13 Plaintiff’s Complaint with prejudice. The bases for this Motion are set forth in the
14 accompanying Memorandum. Language will vary, but typically states something similar –
15 a Memorandum is always accompanied giving the grounds for why you feel it should be
16 dismissed.
17
Dated this 1st day of January, 2010
18
19
20 Attorney
Address
21 Address
22
23
24
25
26
27
28
Motion to Dismiss - 1
www.NorthwestRegisteredAgent.com
1 Attorney
123 Main Street
2 Anytown, US 12345
4
DISTRICT COURT OF ___________________
5
12
FACTS
13
Plaintiff Joe Smith contracted with Defendant ABC Plumbing Inc to do basic
14
plumbing repair at his residence at 100 Main Street on July 1, 2009. A written
15
contract stating the terms of the agreement was agreed to and signed by both parties
16
on the same day. On July 5, 2009, Defendant arrived at the Defendant’s residence and
17
performed all necessary work on the Plaintiff’s bathroom and kitchen. On August 5,
18
2009, Plaintiff alleged that he was taken to County hospital to be treated for 3rd
19
degree burns sustained from a fire in his bathroom. On September 1, 2009, Plaintiff
20
filed a complaint stating he sustained the injuries from a faulty repair job performed
21
by Defendant. This section will continue until all facts are stated.
22
23
ARGUMENT
24
I. Plaintiff’s Complaint Fails To State a Claim Upon which Relief May Be Granted
25
Plaintiff’s claim must be dismissed because his legal claims are without merit.
26
The injuries the Plaintiff sustained were a result of faulty wiring performed by
27
himself or another company, and the plumbing work performed by the Defendant is in no
28
Motion to Dismiss - 2
www.NorthwestRegisteredAgent.com
1 way connected to the injuries. Procedural laws and statutes are typically stated in
2 this section helping to support why the Plaintiff has no claim. Other arguments can be
3 made such as lack of standing, lack of jurisdiction and other specific arguments
5 CONCLUSION
6 For the reason stated above, Defendant’s Motion to Dismiss should be granted.
9
Attorney
10 Address
Address
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Motion to Dismiss - 3
www.NorthwestRegisteredAgent.com