What is normal is the IRAC standard. You write the issue, then the precedent and applicable laws, then you detail how that precedent and laws work for your case, and lastly you write a conclusion.
He's only filed a complete as of yet. When he files a response in opposition to their motion he'll have to make legal arguments or if there's an iota of motion practice after the court rules on the motion to dismiss and compel arbitration (and there won't be).
So this next filing is his only real chance to make a legal argument.
Also as for the complaint, his plights, or at least some of them, would have been relevant to the IIED tort claim. Without that claim in, leaving in the plights shit is surplusage, it currently relates to no relevant fact or legal claim whatsoever.
A fairly good example of IRAC is Fremantle's own motion. If you were to encapsulate it as briefly as possible
Issue: Parties signed a contract with a binding arbitration agreement that essentially anything related to this audition was to be arbitrated. Now Plaintiff is trying to weasel out of that agreement despite having cited nothing wrong about the contract.
Rule: These agreements are routinely enforced.
Analysis: Bunch of string cites with relevant law that in any case remotely similar to this around the whole country and including this Circuit, courts have uniformly upheld them and compelled arbitration.
Conclusion: Dismiss and compel arbitration. And smack his pee pee and call him a dumbass.
Oh and because it seems literally every legal document has to have a mistake in it somewhere:
