Paralegal: You

Letter to Client

Your boss, Carmela, met with a potential client, Elizabeth Moss, who filled out the questionnaire

with her home address as 1000 Somewhere Place, Somewhere, FL 00000. Carmela told

Elizabeth, during their in-person meeting, that she would review her case file and conduct some

initial research because the case was complex.

As Carmela is reviewing the file, she realizes that she cannot represent Elizabeth as she once

represented Elizabeth’s brother, Harold Moss, on a business matter. The business matter

involved his limited liability company which is named ABC, LLC.

Harold Moss and Elizabeth Moss are co-owners of ABC, LLC, and Elizabeth claims that her

brother defrauded her out of money by hiding it. If Carmela represents Elizabeth, it would be a

conflict of interest.

Demand Letter

Please read Florida Statutes 501.98. Section 501.98 et al. explains what is required to sue a

motor vehicle dealer.

Claimant: Johnny Rockets

Address and Telephone Number: 1000 Somewhere Place, Somewhere, FL 00000. 954-555-5555

Dealer: Headquarter Toyota, 74 West Drive, Hialeah, FL 33012, Manager: Miguel Rodriguez

Johnny claims that his brand-new Toyota Camry left him stranded one week after purchasing the

car (1/12/20). He took the car into Toyota to have it looked at. At the time, the mechanics onsite

worked on the car, while Johnny waited in the lobby. Once they were done, Johnny was given

his car back. The mechanics cited the problem as being a loose seal in the gasket. They also

represented to him that he would not have any further issues.

A week later, the air conditioner stopped working. He once again took the car to the dealer. This

time, he asked for a new car. Toyota offered to fix it. but they would not replace the car. Johnny

has the purchase contract and the financing contract. He just received his first bill to make a $200

car payment to the financing company, Chase Bank.

Johnny would like to receive a full refund, or, he will accept a new car but with added upgrades

Toyota must include for free. The cost of the car was $28,000.00. The value of the new car

would be approximately $35,500.00. At all times, Johnny dealt with Miguel Rodriguez and Tony

Danza, the car salesman. He wants this resolved and have Carmela send a letter our on his


Letter to Opposing Counsel

Opposing counsel, Martin Lawrence, Esq., has sent over a settlement agreement regarding a

breach of contract claim. Negotiations have been going on for weeks. Your supervising attorney,

Carmela Jackson, and opposing counsel agreed that Ms. Jackson’s client, Henry Winkler, would

pay $10,000.00 within 10 days of signing the agreement, and would then pay a remaining

$5,000.00 sixty days from the Effective Date of the agreement.

When Martin sends over the proposed agreement, the terms are not what they discussed and

instead, it has Henry paying an additional $10,000.00. The $10,000.00 is an amount Henry is

going to receive from his insurance company for a claim on damages to his house.

Carmela does not agree with this and wants you to compose a letter to opposing counsel about

the additional term not previously agreed upon.