Wednesday, August 14, 2019
Daytime Bakery Company Essay
To the above named defendant: Daytime Bakery Company à à à à à à à à à à à Take notice that: On January 31, 2007 at 9:00a.m., in the District Court, Greendale, Georgia, if an answer is not filed, the court may be asked to enter judgment against you as set forth by the complaint. A copy of the complaint is attached. If you do not agree with the complaint then you must either: Go to court, located at 149 Blooms Street, Greendale, Georgia at the above date and time and file an answer stating any legal reason you have why judgment should not be entered against you, or File an answer with the court before that date and time. If you file an answer, you must give or mail a copy to the Plaintiffââ¬â¢s attorney who signed the complaint. If you do not file an answer or appear at the hearing, then the court may enter default judgment against you for the relief requested in the complaint. Michael Monroe Attorney at Law 522 Law Office Lane Georgia, CO 805111 352-121-5152 FAX: 352-111-5322 monroepractice.com monroeatlaw@aol.net June 13, 2007 Anthony Craig Manager, Albuquerque Flames P.O. Box 1123 Northville, Albuquerque RE:à à à à à Demand for Compensatory Relief Dear Mr. Craig: I am representing one Randy Offerdahl who is seeking for compensatory relief from your professional football team, Albuquerque Flames. My client claims that he was denied the opportunity to try out as a kicker for the team on the unfair grounds of his having epilepsy. My client is complaining the said discrimination and is claiming that he would have made the team and earned a $300,000.00 contract had he been given the chance. My client has played against 40% of the current Albuquerque Flames team members during his college football career, and claims that he can hold his own against them. This letter serves as a demand for compensatory relief in the amount of Fifty Thousand Dollars ($50,000.00) to be paid in certified funds no later than June 30, 2007. This amount and any future correspondence should be sent directly to the undersigned. I trust that you will consider this option seriously so as to avoid additional attorneyââ¬â¢s fees should this issue remain unsettled by the administered deadline. You may have your attorneys contact my office regarding any questions that you might have. DISTRICT COURT COUNTY OF GREENDALE, GEORGIA COURT USE ONLY Plaintiff: John Evans à v. à Defendant: Daytime Bakery Company Roger H. Wilder Case No.: 00CV1003 à à à à à à à à Div: 8à à à à à à à à à à à Ctrm: 3 Attorney for the defendant 503 Law Office Lane Georgia, CO 805123 à 352-134-5851 FAX: 352-134-5821 rogersfirm@aol.net Registration #: 1141 ANSWER à à à à à à à à à à à à à à The defendant, Daytime Bakery Company, by and through its counsel, Roger H. Wilder, for its answer states and alleges as follows: à 1.à à à à The defendant is well aware of Ordinance # 115 and is in full compliance with its statues. à 2.à à à à The defendant admits the allegation that the sidewalk outside Daytime Bakery Company has not been shoveled for the past four (4) days prior to the plaintiffââ¬â¢s accident. à 3.à à à à The defendant claims that despite of this, salt was consistently being applied on it on a daily basis in order to prevent any accidents as in compliance with Ordinance # 115. à à AFFIRMATIVE DEFENSE à 1.à à à à The plaintiffââ¬â¢s own carelessness caused his accident. à WHEREFORE, the defendant hopes that the plaintiff recovers nothing by reason of his Complaint and that his Complaint be dismissed. à Defendantââ¬â¢s Address: P.O. Box H, Carlton Ave. Greendale, Georgiaà 18941-0508 à Respectfully Submitted: à _________________________ Roger H. Wilder #1141 Attorney for Defendant à DISTRICT COURT COUNTY OF GREENDALE, GEORGIA COURT USE ONLY Plaintiff: Kim Latros à v. à Defendant: Officer Harry Davis Roger H. Wilder Case No.: à à à à à à Div:à à à à à à à à à à à à à à Ctrm: 503 Law Office Lane Georgia, CO 805123 à à 352-134-5851 FAX: 352-134-5821 rogersfirm@aol.net Registration #: 1141 COMPLAINT à à à à à à à à à à à à à The plaintiff, Ms. Kim Latros, by and through her counsel, Roger H. Wilder, for her complaint against the defendant alleges as follows: à 1.à à à à Plaintiff is a citizen of Georgia, residing at 1511 Greenwood Street, Greendale, Georgia. The incident occurred in the state of Georgia, County of Greendale. à 2.à à à à The defendant is an office of the Georgia Police Department à 3.à à à à On June 8, 2007, the plaintiffââ¬â¢s car was pulled over by the defendant supposedly because the carââ¬â¢s license tags were expired. When the plaintiff got out of the car and checked that the tags were not expired, the defendant placed her in handcuffs, read her her Miranda rights, and placed her under arrest for carrying a concealed weapon. The defendant brought her to Georgia Police Department, all the time ignoring her admonitions that she had a permit for the weapon which she was able to produce later on. à 4.à à à à The plaintiff has since the incident, suffered from psychological trauma because of the defendantââ¬â¢s actions. à Note: Middle Portion of Document Intentionally Missing à WHEREFORE, the plaintiff prays for judgment against defendant in an amount to be proven at the time of the trial, including psychiatric bills, emotional damages, and costs in filing this suit, interest from the date of commencement of this action, expert witness fees, attorneyââ¬â¢s fees, and for such other and further relief as to this Court may seem just and proper. à THE PLAINTIFF DEMANDS THAT THIS ACTION BE TRIED BY JURY à Plaintiffââ¬â¢s Address: 1511 Greenwood Street, Greendale, Georgia Respectfully Submitted: _______________________ Roger H. Wilder #1141 Attorney for Plaintiff
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