LEGAL WRITING - SAMPLE INITIAL PLEADING

VIRGINIA:

IN THE CIRCUIT COURT OF FAIRFAX COUNTY

JOHN W. JONES

Plaintiff

v. AT LAW NO.

XYZ CORPORATION

Defendant

Serve: Thomas S. Thorne

Registered Agent

2233 Main Street, #3

Richmond, Virginia 33333

MOTION FOR JUDGMENT

COMES NOW the plaintiff, John W. Jones, by counsel, T. Robbins Joyner, and

respectfully moves for judgment against the defendant, XYZ Corporation, on the grounds and in

the amount as hereinafter set forth:

1. Defendant is a corporation organized under the laws of the Commonwealth of Virginia,

having an office and principle place of business at 1000 Needle Street, Richmond, Virginia.

2. Defendant is the owner and operator of the Kelly Department Store, located at 222

Earle Street in Fairfax County, Virginia.

3. On May 15, 1987, as the plaintiff was preparing to leave the Kelly Department Store

after completing his shopping, he was placed in restraint without any legal cause by Thomas A.

Forte, store manager.

4. The plaintiff was taken to the manager=s office, searched ans accused of the theft of a

socket wrench, which was in fact never found.

5. The plaintiff was detained for two hours before being released.

6. The restraint of the plaintiff=s liberty by the store manager was without probable

cause or legal excuse and constituted false imprisonment.

7. As a direct and proximate result of the actions of Thomas A. Forte, the defendant=s

agent and employee, acting within the scope of his employment, the plaintiff was greatly

injured in his reputation in the community, was subjected to public scorn and ridicule, and

was caused great mental anguish and anxiety.

WHEREFORE, the plaintiff demands judgment against the defendant in the amount of

fifty thousand dollars.

_____________________________________

JOHN W. JONES

By Counsel

Submitted by:

_______________________________

T. ROBBINS JOYNER

Counsel for the plaintiff

1000 Main Street #111

Fairfax, Virginia 22222

(703)555-1111