Plaintiff Fred Jones (Jones) arrives at the law offices of Barney Fife where you work as a paralegal Jones says he slipped and fell on a sidewalk in front of his Los Angeles City apartment house Jones hurt his right knee which was bleeding profusely. He went to the hospital where they did an X-ray and MRI scan and determined the kneecap to have a slight fracture on the patella (the bone covering the knee joint). Jones paid for his medical care using his own health insurance Jones is in a cast and still exhibiting scrapes on his hands and face from his impact with the sidewalk

Jones wants to hire attorney Barney Fife to represent him You talk the case over with your boss Barney, who tells you to sign up Jones as a client and to draft two letters for Barney's signature. In the first letter, Barney will demand money, an agreement to fix the sidewalk, and a public apology from the City of the Los Angeles In the second letter, Barney will demand that the apartment house owner also pay for Jones injuries Lastly, Barney tells you to state in the two letters that if the City or apartment house owner do not agree to Barney's demands, he will hold a press conference at which he will denounce both the City and the apartment house owner for almost killing Jones through their actions.

Question 1: What additional things should you have asked client Jones about during your first interview with him, prior to his being signed up as a client? Why? Question 2: What additional steps might you take to prepare the case now that Jones is a client? Why? Question 3: What concerns if any would you express to Barney over his demand letters before they go out? Why? Question 4: If the defendant tries to stop the press conference by trying to get an injunction as part of its defamation cross-complaint, what Motion can you file to stop this cross-complaint and why might it succeed?