IN THE UNITED STATES DISTRICT COURT,
SOUTHWESTERN DISTRICT, TEMPE, ARIZONA
CASE NO. B19294, JUDGE JOAN KUJAVA, PRESIDING
___________, Plaintiff
-v.-
____X____, Defendant
Opening Statement of Mr. Harold Schoff, attorney for Mr.__________:
My client, Mr. ____________, a resident of Arizona and contiguous states, does hereby bring suit for damages against the _____X_____, manufacturer and retail distributor of assorted merchandise, incorporated in Delaware and doing business in every state, district, and territory. ___________ seeks compensation for personal injuries, loss of business income, and mental suffering causes as a direct result of the actions and/or gross negligence of said company, under Title 15 of the United States Code, Chapter 47, section 2072, subsection (a), relating to product liability.
Mr.____________ states that on eighty-five separate occasions he has purchased of the _____X______(hereinafter, "Defendant"), through that company's mail-order department, certain products which did cause him bodily injury due to defects in manufacture or improper cautionary labelling. Sales slips made out to ____________ as proof of purchase are at present in the possession of the Court, marked Exhibit A. Such injuries sustained by Mr._____________ have temporarily restricted his ability to make a living in his profession of predator. Mr._____________ is self-employed and thus not eligible for Workmen's Compensation.
(Some inbetween stuff has been omitted for the sake of brevity...and because you horribly smart people will get it anyway)
Paragraph One of the Report of Attending Physician (Exhibit B), prepared by Dr. Ernest Grosscup, M.D., D.O., details the multiple fractures, contusions, and tissue damage suffered by Mr. __________as a result of this collision. Repair of the injuries required a full bandage around the head (excluding the ears), a neck brace, and full or partial casts of all four legs.
(Again, omission of stuff)
As the Court is no doubt aware, Defendant has a virtual monopoly of manufacture and sale of goods required by Mr.___________ 's work. It is our contention that Defendant has used its market advantage to the detriment of the consumer of such specialized products as itching powder, giant kites, Burmese tiger traps, anvils, and two-hundred-foot-long rubber bands. Much as he has come to mistrust Defendant's products, Mr.___________ has no other domestic source of supply to which to turn. One can only wonder what our trading partners in Western Europe and Japan would make of such a situation, where a giant company is allowed to victimize the comsumer in the most reckless and wrongful manner over and over again.
Mr.___________ respectfully requests that the Court regard these larger economic implications and assess punitive damages in the amount of seventeen million dollars. In addition, Mr._________ seeks actual damages (missed meals, medical expenses, days lost from professional occupation) of one million dollars; general damages (mental suffering, injury to reputation) of twenty million dollars; and attorney's fees of seven hundred and fifty thousand dollars. Total damages: thirty-eight million seven hundred and fifty thousand dollars. By awarding Mr.__________ the full amount, this Court will censure Defendant, its directory, officers, shareholders, successors, and assigns, in the only language they understand, and reaffirm the right of the individual predator to equal protection under the law.
Just id X.
Easy.
And get the theme! :)
