Motion to Dismiss for Failure to State Claim

[Caption]

MOTION TO DISMISS

Defendant [Name] by and through [his/her] attorney [Name of Attorney], and pursuant to 735 ILCS 5/2-615, brings this motion to dismiss Plaintiff [Name]’s complaint for failure to state a cause of action, for the following reasons:

  1. Plaintiff filed this complaint on [Date], alleging that plaintiff cut [his/her] hand on a scalpel while emptying a wastebasket at work. The defendant [Name] for whom plaintiff works, was later diagnosed with an AIDS related...

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