Whereas, on or about the night prior to Christmas, there did occur at a certain
improved piece of real property (hereinafter "the House") a general lack of
stirring by all creatures therein, including, but not limited to a mouse.
A variety of foot apparel, e.g. stocking, socks, etc., had been affixed by and
around the chimney in said House in the hope and/or belief that St. Nick a/k/a/
St. Nicholas a/k/a/ Santa Claus (hereinafter "Claus") would arrive at sometime
The minor residents, i.e. the children, of the aforementioned House, were
located in their individual beds and were engaged in nocturnal hallucinations,
i.e. dreams, wherein vision of confectionery treats, including, but not limited
to, candies, nuts and/or sugar plums, did dance, cavort and otherwise appear in
Whereupon the party of the first part (sometimes hereinafter referred to as
"I"), being the joint-owner in fee simple of the House with the parts of the
second part (hereinafter "Mamma"), and said Mamma had retired for a sustained
period of sleep. (At such time, the parties were clad in various forms of
headgear, e.g. kerchief and cap.)
Suddenly, and without prior notice or warning, there did occur upon the
unimproved real property adjacent and appurtent to said House, i.e. the lawn, a
certain disruption of unknown nature, cause and/or circumstance. The party of
the first part did immediately rush to a window in the House to investigate the
cause of such disturbance.
At that time, the party of the first part did observe, with some degree of
wonder and/or disbelief, a miniature sleigh (hereinafter the "Vehicle") being
pulled and/or drawn very rapidly through the air by approximately eight (8)
reindeer. The driver of the Vehicle appeared to be and in fact was, the
previously referenced Claus.
Said Claus was providing specific direction, instruction and guidance to the
approximately eight (8) reindeer and specifically identified the animal
co-conspirators by name: Dasher, Dancer, Prancer, Vixen, Comet, Cupid, Donder
and Blitzen (hereinafter the "Deer"). (Upon information and belief, it is
further asserted that an additional co-conspirator named Rudolph may have been
The party of the first part witnessed Claus, the Vehicle and the Deer
intentionally and willfully trespass upon the roofs of several residences
located adjacent to and in the vicinity of the House, and noted that the Vehicle
was heavily laden with packages, toys and other items of unknown origin or
nature. Suddenly, without prior invitation or permission, either express or
implied, the Vehicle arrived at the House, and Claus entered said House via the
Said Claus was clad in a red fur suit, which was partially covered with residue
from the chimney, and he carried a large sack containing a portion of the
aforementioned packages, toys, and other unknown items. He was smoking what
appeared to be tobacco in a small pipe in blatant violation of local ordinances
and health regulations.
Claus did not speak, but immediately began to fill the stocking of the minor
children, which hung adjacent to the chimney, with toys and other small gifts.
(Said items did not, however, constitute "gifts" to said minor pursuant to the
applicable provisions of the U.S. Tax Code.) Upon completion of such task, Claus
touched the side of his nose and flew, rose and/or ascended up the chimney of
the House to the roof where the Vehicle and Deer waited and/or served as
"lookouts." Claus immediately departed for an unknown destination.
However, prior to the departure of the Vehicle, Deer and Claus from said House,
the party of the first part did hear Claus state and/or exclaim: "Merry
Christmas to all and to all a good night!" Or words to that effect.