Motion to Strike

[Caption]

MOTION TO STRIKE

Defendant [Name], by and through [his/her] attorney [Name of Attorney], and pursuant to 735 ILCS 5/2-615, brings this motion to strike certain allegations of plaintiff [Name]’s complaint as follows:

  1. On [Date], plaintiff [Name] filed a complaint against defendant [Name] under a negligence theory.

  2. In paragraph 5 of Count I, plaintiff enumerates a number of allegations explaining how defendant was negligent, including paragraph 5(d), which reads as follows:

    “Defendant [Name] was otherwise negligent.”

  3. Paragraph 5(d) of Count I is conclusory in nature and, as such, is improper and should be stricken.

    WHEREFORE, defendant [Name] asks this court to strike paragraph 5(d) of Count I from the complaint.

    Respectfully...

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