Additional Cause of Action – Legal Malpractice

VERIFIED COMPLAINT

&BLANK& CAUSE OF ACTION

                    (Legal Malpractice Against &DependentCounsel& and Does 51-250)

1. Plaintiff realleges foregoing paragraphs 1 through &Blank& and incorporates them herein by reference.
2. &DependentCounsel& has an attorney-client relationship with &Client&.
3. &DependentCounsel& has a duty to &Client& to use such skill, prudence, and diligence as attorneys commonly possess and exercise.
4. &DependentCounsel& breached the duty to &Client& to use such skill, prudence, and diligence as attorneys commonly possess and exercise.
5. &DependentCounsel&’s breach of the duty to &Client& caused damage to &Client&.