FACTS:

Ten year-old Ronald Smith lives at 1234 Any Street in City, State, with his parents Jim and Mary Smith.Two houses away, at 1236 Any Street, is a vacant house owned by David Richards who rents it. A tenant was scheduled to move in on Monday, August 1, 2020.On a nice summer day, Friday July 21, 2020, Midtown Electrical Company broke part of the sidewalk to install a new street light.They completed the job and left the sidewalk partially broken around the new pole.They intended to return on Monday July 24, 2020, to cement it; however, they did not get around to it.

On Saturday, July 29, 2020, Ronald was riding his scooter up and down the sidewalk.He then tripped over the missing block of concrete where Midtown Electric Company put the pole in at 1236 Any Street.In the fall, Ronald sustained injuries to his face, including a laceration requiring stitches, a permanent scar, a chipped tooth, and other cuts, scrapes and bruises. His $50 scooter and his $150 eye glasses were broken.The next day, July 30, 2020, Midtown Electric Company repaired the sidewalk and the new tenant moved in as scheduled on August 1, 2020.

After the fall, Ronald went to the emergency room of Mercy Hospital.He later saw a dentist, plastic surgeon, eye doctor and his pediatrician. Since Midtown Electric Company fixed the sidewalk, Jim and Mary Smith have incurred medical bills and expenses as a result of Ronald's treatment. They hired a lawyer to sue the responsible parties.

A. Directions:Prepare 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 prepare 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 Paralegals for dummies book