I need help completing this assignment:

WRITTEN ASSIGNMENT #1

Drafting a Complaint

Instructions:

Please follow the instructions in the hypothetical interoffice memorandum below.As you can read in the memorandum, your tasks are two-fold:(1) finish drafting a complaint for Patt v. Donner, and (2) drafting an email to Patt answering various questions.

INTEROFFICE memorandum

To:Student-Associate

From:Professor-Partner Pelligrino

Re:Patt v. Donner

Thank you for your work on behalf of Ms. Patt.Your team's legal research on her Federal Fair Housing Act claim (Case File, page 37)[1] was superb.Another part of Patt's litigation team drafted a portion of Ms. Patt's complaint which can be found in the Case File, pages 39-43.An electronic version of this complaint is available on line.I would like you to finish the draft complaint and be prepared to explain your work to Ms. Patt.

In particular, I would like you to do the following two tasks:

TASK #1: Finish drafting the complaint.Specifically, download the electronic version of the complaint onto your computer (to keep the numbered pleading paper) and:

a.Finish drafting the "Statement of Facts" (also known as the "Statement of the Claim").This means, starting with Paragraph 8 (and using as many additional numbered paragraphs as needed), allege whatever additional facts, if any, you deem necessary.Add and change paragraph numbering as necessary.Please note, our investigation team visited the apartment building on two consecutive weekends and confirms that they did not see any children present on the building's premise or coming out of the specific apartment Patt had applied to rent.

b.Draft "Count 1," P's claim for a violation of the Fair Housing Act.This is a missing section starting at paragraph 16.This section should establish a short and plain statement of the prima facie claim as required by Federal Rules of Civil Procedure, Rule 8.You can begin with a clear heading, followed by what is numbered as Paragraph 16 in the electronic version of the complaint.Add and change paragraph numbering as necessary.

Remember to review your team's legal research on a Federal Fair Housing Act claim (Case File, page 37) which provides four elements to bring such a claim: [2]

1.Plaintiff is a member of a protected class.

2.Plaintiff applied for the apartment and was qualified to rent it.

3.Plaintiff was not accepted as a tenant.

4.The apartment remained vacant or Defendant rented the apartment to another tenant who was not a member of the protected class to which Plaintiff belongs.

Also, remember that all complaints are subject to Rule 11.

TASK #2: draft an email to our client, Ms. Patt, in which you explain the purpose of the complaint.It is important that Ms. Patt understand what we are filing and why.Address the email to Ms. Patt and please briefly (about one page or less) explain to her the purposes of the following portions of the complaint as it is drafted in the Case File (use the complaint in the book, Patt v. Donner, instead of the electronic version of the complaint so that it is clear what is referenced below):

a.Caption (page 41 of the Case File, Patt v. Donner, lines 1-17) - What information does the caption provide? Why are we demanding a jury trial both in the caption and on page 43, lines 19-20?

b.Why does paragraph 2 start with "Upon information and belief"?

c.What is the purpose of paragraphs 4-5?

d.What is the purpose of paragraphs 6 and 7?

e.In the Prayer for Relief section, paragraphs 16-21, what types of remedies are sought, and, what are the differences between them?What is the purpose of the last line in this section (page 43, line 18)?

As far as formatting, please use one document for all tasks.The draft email should comprise the last page of your complaint.Please make clear (with labels and headings) which task you are addressing.

We will go over these tasks the next time we meet.While you do not need to draft a summons, please be prepared to discuss what you might include in a summons.To help get started, you may want to review Rules 3, 4, 7, 8, and 9.

Ms. Patt's complaint will be filed in the United States District Court, Northern District of California.Here is the website of the area this federal district court covers: http://www.cand.uscourts.gov/jurisdictionmap.I have a colleague in Los Angeles, California, who is representing a client in a similar matter.I wonder what federal district court my colleague's Los Angeles case should be brought in?Here is another website that might be helpful: https://www.cacd.uscourts.gov/jurisdiction.We will talk about this when we next meet.

Thank you in advance for your efforts.

[1] All page references are to the Patt v. Donner book.

[2] For further discussion of the elements of the claim, you can review the Casefile pages 96-97.