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Comply With the Relevant Federal, State, and Local Rules. Research Before Writing. Allege Subject Matter Jurisdiction, Personal Jurisdiction, and Venue. Jurisdiction. Draft Concise and Plain Statement of the Facts. Factual Allegations. Draft Separate Counts for Each Legal Claim. Plead Facts With Particularity Where Necessary.
Cause of ActionGeneral Negligence (PLD-PI-001(2)) Tells the court and the other side that you contend the other side was negligent in some way, and that you were harmed as a result.
Negligence is a broad and long-recognized cause of action under which an aggrieved party the plaintiff may recover damages if he can prove that (1) the defendant owed him a duty of care, (2) the defendant breached that duty by failing to act in a reasonable, careful manner, (3) the defendants violation of his duty
A cause of action arises wherever there is proof that there was the existence of a duty towards the plaintiff by him which he failed to procure resulting in a breach. For instance, negligence as a Tort is a breach of duty that is not desired by the plaintiff but committed by the defendant.
The complaint describes the plaintiffs damages or injury, explains how the defendant caused the harm, shows that the court has jurisdiction, and asks the court to order relief.
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If the driver breaks the law, that conduct could be a direct cause of a car crash, For instance, suppose a driver runs a red light and crashes into another vehicle. The car crash would not have occurred but for the driver running the red light. Therefore, running the red light is a direct cause of the accident.
COMPLAINTContract (PLD-C-001) Tells the court and the other side that you are starting a lawsuit based on breach of contract or a similar theory, and the general allegations you are making against the other side.
For example, a truck driver or motorist has a duty to other motorists on the road to follow laws and drive responsibly. The driver would violate that duty by running a red light or driving recklessly, and it would be foreseeable that a crash could result from such actions.

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