A. Directions: A Complaint on behalf of the Smith's from the demand letter scenario. You should sue all responsible parties. You may use the generic format as illustrated in the PCD book.

NOTE: you may embellish any needed facts for the Complaint including the amount of any medical bills for each provider or medical liens owed, lost wages, if any, and all out of pocket expenses. Make sure the embellished facts support the claim and remain within the given factual framework. Be sure to explain liability for all responsible parties and damages including pain and suffering. Feel free to use your city and state and any attorney names, addresses etc. should be fictional.

B. Directions: Now an Answer to the Complaint on behalf of one of the defendants named in your Complaint. You may use the generic format as illustrated in the PCD book.

Demand Letter:

In this case, the responsible party would be Midtown electrical company because it was the company negligent that caused injuries to Ronald.

Midtown Electrical Company

XXX

XXX

Dear Sir,

You recently installed a new street light but you left the sidewalk partially broken around the new street light pole. You intended to return on Monday 24th July 2020 to repair the broken part but you did not make it.

On Saturday, July 29, 2020, my child Ronald was riding my scooter up and down the sidewalk. He tripped over the missing block of concrete where your Company put the pole in at 1236 Any Street. In the fall, he sustained injuries to his face, including stitches, a permanent scar, a chipped tooth, and other cuts, scrapes and bruises. His scooter worth $50 and his eyeglasses worth $150 were broken. After the fall, I went to the emergency room of Hope Hospital. I had an appointment with the dentist, plastic surgeon, eye doctor and pediatrician for my kid. It was your company's responsibility to make sure that no part of the sidewalk was left broken because it could be dangerous for the residents. But your company ignored the fact and left the sidewalk broken that caused injuries to my child, Ronald. Since your company fixed the sidewalk, we have incurred medical bills and expenses as a result of my kid's treatment.

Please forward $1,200.00 (the cost of my child's injury and medical bill) within ten days. If I don't receive your revert by this date (XXXX) then I will promptly file a lawsuit in small claims court against your company and this letter will be tendered in court as evidence of your failure to attempt to resolve the matter. Therefore, you will be liable for any court cost, lawyer fees, and damages.

Yours sincerely

Jim Smith

1234 Any Street