This pleading is offered as a sample for educational purposes only.  References to law and rules may not be current or accurate.  Counsel must evaluate whether the pleading has utility in a given case.  I am always happy to try to answer general questions of fellow counsel about law and practice and can be reached [...]

This pleading is offered as a sample for educational purposes only.  References to law and rules may not be current or accurate.  Counsel must evaluate whether the pleading has utility in a given case.  I am always happy to try to answer general questions of fellow counsel about law and practice and can be reached [...]

This pleading is offered as a sample for educational purposes only.  References to law and rules may not be current or accurate.  Counsel must evaluate whether the pleading has utility in a given case.  I am always happy to try to answer general questions of fellow counsel about law and practice and can be reached [...]

This pleading is offered as a sample for educational purposes only.  References to law and rules may not be current or accurate.  Counsel must evaluate whether the pleading has utility in a given case.  I am always happy to try to answer general questions of fellow counsel about law and practice and can be reached [...]

This pleading is offered as a sample for educational purposes only.  References to law and rules may not be current or accurate.  Counsel must evaluate whether the pleading has utility in a given case.  I am always happy to try to answer general questions of fellow counsel about law and practice and can be reached [...]

This pleading is offered as a sample for educational purposes only.  References to law and rules may not be current or accurate.  Counsel must evaluate whether the pleading has utility in a given case.  I am always happy to try to answer general questions of fellow counsel about law and practice and can be reached [...]

This pleading is offered as a sample for educational purposes only.  References to law and rules may not be current or accurate.  Counsel must evaluate whether the pleading has utility in a given case.  I am always happy to try to answer general questions of fellow counsel about law and practice and can be reached [...]