draft an appropriate complaint

You work as a paralegal in a personal injury practice located in the hypothetical state of Freedonia. Deirdre Jones walks into your office and asks to speak to you and an attorney. At the meeting, Deirdre tells you the following:

So, last Friday I was hanging out and, all of a sudden, this guy comes up to me and grabs my purse which I was wearing and starts running away. So, I ran after him. He picks up a rock and just throws it at me. So I duck and it misses me. But, sadly for him, I am a two time World Cup sprinting medalist and I tracked him down, in 8 seconds. I grabbed my pocketbook back and he starts yelling at me and says “You stupid b—-, drop dead!” I was really hurt inside. I turned around and went home. When I got home, I realized that my wallet had fallen out of the purse while he was running with it, and I lost the wallet, which had $60 in cash and many other important personal items.

Deirdre then tells you that she later found out that the mugger’s name is Jack Daniels. She also makes it 100% clear that she wants to sue Mr. Daniels for every cause of action you can think of.

You are asked to please draft the complaint to be filed in state court. Assume that the state court had jurisdiction over the case based on Rule 1.1 of the Fredonia State rules of litigation. Please draft an appropriate complaint, making sure to allege as many causes of action as can be reasonably alleged. You may (and should) use a sample complaint from the “documents” page on the student website. However, realize that the torts and elements are different in this case than in that document.

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