Have you ever wondered why most judges will grant one or two defense motions to dismiss a civil complaint? The answer is that too many attorneys shoot from the hip and draft complaints without researching relevant case law first in order to cover cause of action elements. Many attorneys educate themselves backwards looking, working off of the judge's written Order dismissing the complaint without prejudice. Of course it's time consuming to do your legal research in advance of filing, but if you have a complex case with a multitude of technical legal issues, chances are you will only be granted leave of court to amend a couple times before the court dismisses your case with prejudice. The smart thing to do instead is to complete due diligence legal research and then write your own memorandum of law, prior to drafting your civil complaint. You will be more prepared in the long run and you will gain more credibility with the court as a result.