Draft a Complaint with all appropriate allegations, and all applicable causes of action (there

clearly is more than one cause of action that should be pled), and in the correct format as

was taught in class. Also, include all appropriate Defendants.

FACT PATTERN:

Your client, Jose Rodriguez, purchased a used Porsche for

$40,000.00 from his good friend Bill Tobacco, who works as a car

salesman at the EyeGotU Car Dealership.

When leaving, Bill told Jose he has a side business selling electric

cigars, and convinced Jose to buy one at the cost of $5,000.00.

When walking out of the car dealership, Jose was fascinated by the

cigar and slipped and fell in some liquid on the floor severely

injuring his back, hip, and elbow. Later that night Jose was trying

to relax, and decided to try out his electric cigar when it blew up in

his face causing severe burns.

Making matters worse, because Jose couldn’t drive his car home

(following the slip and fall) the car was delivered to his home a

month later, at which time Jose learned that his “Porsche” has a

Volkswagen engine.

Jose wants to sue for any and all claims. Prepare the client

questionnaire.