'o: Paralegal Support From: Christopher B. Ellison, Esq. Re: Ringer v. Springhead Date: September 9, 2019 I just met a client, Bubbles Ringer, who owns a mailbox and shipping store in Los Angeles called MAIL IT! She is having a dispute with Brian Springhead, a former co worker and paralegal, who provided consulting services to help her start her business. In January 2019, Springhead and Ringer met while still working together and agreed orally that she would pay him $10,000 as a consulting fee for his time and knowledge in launching her new mail business. The fee would be paid once the store turned a profit. For the next two months, they worked together in the evenings where he gave her advice on a number of issues. Some of Springhead's advice turned out to be bad. Specifically, he reviewed her proposed two-year lease which did not include an option to renew at a specified rate. When the lease ran out, the landlord charged her an additional $550 in rent to stay for the next two years, at least $300 more than market rent, because the landlord knew that she would not want to move. Springhead also advised her to incorporate, which costs her $800 per year for the fee to the Secretary of State, even though she is completely insured for $2,000,000 in coverage as required by her landlord, and all her vendors required her to sign guaranties anyway. She has gotten no benefit from having limited liability for the last two years. Most importantly, he failed to advise her to get an agreement from UPS that it would not contract with a competitor within one mile of her store. MAIL IT! is an agent for these companies and gets many customers who want to use these courier services. Six months ago, a competitor opened up across the street and advertises these same courier services. She has seen her business drop off by 20% since that store opened and she thinks she's losing about $2500 a month in commissions. Springhead has started to demand payment. At this point, Ringer is thinking of filing an action against him for the damages caused by his bad advice. Draft a complaint against Springhead. Relevant forms: e a civil case cover sheet e a civil case cover sheet addendum asummons e a proof of service