Author: admin

Your client
needs to give testimony at a deposition on November 15, at 10 A.M. at your
offices. Please draft a letter asking William Hesse to be at the deposition.
Explain to him that you will meet with him in advance to discuss his testimony.

Your firm
has just settled a case involving Karen Douglas and your client, the Wentworth
Industries, in Morristown, New Jersey. The case was settled for $88,000. The
Wentworth corporation paid Douglas for injuries she sustained when she fell at
a Mexican hotel. You do not want to admit any liability in your letter or admit
any ownership interest in the Mexican hotel, the CanCan. You merely want to
tender the check to Douglas in full satisfaction of any claims she or her
husband have against Wentworth. You also have the signed settlement agreement
to send her and the court dismissal of the action.

You are
assigned the preparation of a letter that explains the status of a pending
insurance defense litigation matter. The matter is set for trial on November 15
of this year. Two depositions have been taken—the plaintiff’s and the
defendant’s. Interrogatories have been answered by both sides and a settlement
conference is scheduled with the judge in the case on October 31. The judge is
Eve G. Halsey of Ohio Common Pleas Court in Columbus, Ohio. You expect that a
representative of the restaurant where the incident took place will attend the
settlement conference and that an insurance company representative also will
attend as required by the local court rules. Your firm will be calling several
witnesses from the restaurant to testify at the trial and you and the partner
on the case, Wally Taylor, will be preparing these witnesses to testify
beginning in October. Send this letter to your client, Schroeder Insurance
Enterprise, 250 W. Wilson Street, Hinsdale, IL 60521. The person you deal with
at the insurance company is Thomas Kennedy, a claims manager. You are sending
this letter via Express Mail. The letter is being typed by Taylor’s secretary
Jan Marie Maggio. She will send a blind copy of the letter to an associate on
the case, Janis Farrell. She also will send a carbon copy of the letter to Mr.
Taylor.

Prepare a
letter to Attorney Gene Williams of the Law Office of Gene Williams, 20 E.
Washington Street, Chicago, Illinois 60611. You want to tell Mr. Williams that
you are sending him a copy of a real estate contract between your clients,
Laura and James Hirsh, and his clients, Michelle and Jordan Bream, for the
purchase of 2629 Canterbury Lane, Northbrook, Illinois 60062. You also are
including a $41,000 certified check for the escrow for the property. This
represents 10 percent of the purchase price. The closing is tentatively set for
April 1 of this year. The letter is being hand-delivered by a messenger from
your law firm. The letter is being typed by your secretary, Carly Alice
Connelly. A blind copy is being sent to the partner on the case, Wally Taylor.

You are
responsible for mailing interrogatories to the plaintiff’s lawyer, Joanna Mark,
at the Law Office of Joanna Mark, 25 E. Randolph Street, Chicago, Illinois
60611. You complete the interrogatories on October 30 of this year at 11 P.M.
What date should you put on the letter, and what date will the letter be
mailed? Draft this letter. Your secretary, Carly Alice Connelly, will be typing
the letter, and a carbon copy should be sent to the partner, Alicia Coffield.