A. Directions:Do 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 theComplaintincluding 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 Do 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.

Here is Demand Letter:

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

Amy Bernstein, Esq.

Law Offices of Amy Bernstein

789 Apple Street,

San Diego, CA 98930

(222) 496-7890 Fax: (222) 496-7891

January 30, 2021

Tom Toms

Midtown Electrical Company

567 Property Drive

San Diego, CA 98930

Dear Mr. Tom Toms,

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.

Therefore Ronald Smith has had to go to the emergency room, see a dentist, plastic surgeon, eye doctor, and his pediatrician. The medical bills alone total two hundred and sixty-three thousand dollars ($263,000). The injuries to his face will require him to have to endure two more plastic surgeries. That will roughly be eighty-seven thousand dollars ($87,000). His scooter, costing fifty dollars ($50), were broken, as well as his eyeglasses, which cost one hundred and fifty dollars ($150). He also suffered emotional damages, pain, and suffering. Mary Smith had to take time out of work to care for Ronald Smith after his accident and demands compensation for lost wages in the amount of ten thousand, three hundred and seventy-eight dollars ($10,378). This letter serves as a demand for settlement in the amount of Four Hundred and Forty-Four Thousand Dollars ($440,000) to be paid by certified funds, no later than March 2, 2021. The settlement amount and any future correspondence should be sent directly to the undersigned. Please do not hesitate to have your attorneys contact my office should you have any questions.

Yours sincerely,

Amy Bernstein

Cc: Jim & Mary Smith