WHEREFORE PREMISES CONSIDERED?
Is it okay to eliminate phrases like WHEREFORE PREMISES CONSIDERED and other such verbiage from the prayer in a complaint? And what is the proper substitute?
Yes, it is okay to eliminate these words. In fact, I highly recommend it.
First, let's be clear that there is no need to put the phrase in ALL-CAPS. Legal-writing experts agree that the use of ALL-CAPS hampers readability. Bryan A. Garner, A Dictionary of Modern Legal Usage 130 (2d ed., Oxford U. Press 1995); Irwin Alterman, Plain and Accurate Style in Court Papers 17-18 (ALI-ABA 1987).
Second, the phrase is not necessary. Alterman, Plain and Accurate Style in Court Papers at 56. It's just archaic baggage. And its use in the phrase you've asked about is inarticulate: "one who writes 'wherefore premises considered' in the prayer of a court paper would be hard pressed to say what the premises are, other than everything that has gone before." Garner, A Dictionary of Modern Legal Usage at 685.
Third, there are simple substitutes. Alterman suggests "Plaintiff requests the court . . ." Alterman, Plain and Accurate Style in Court Papers at 55. "The plaintiff asks . . ." may work as well. Some omit the phrase and use a heading like "Prayer" without any further lead-in.