There my materials below. I want to ask how to write statement of fact in memo, can I get an example?

And I've brought the deed with me today. It shows that I purchased about 50

acres from Nick Carlo in January 2006. It's the location of my musicians' retreat, Birch Creek

Colony, north of Fairbanks.

Ms. Travis: Thank you. So you came to our firm for some legal advice. What's going on?

Ms. Kim: Nick Carlo, you might have heard of him, he owns Carlo Resort and Horse Ranch.

Anyway, he claims that he still owns a piece of property that I bought from him 15 years ago.

We've been using it since I purchased it from him. Nick claims to be the so-called owner of

record to four cabins and their surrounding property that he sold me in 2006. The property is part

of the 50 acres that I bought from him. It does not belong to him. It's mine.

Ms. Travis: Where is the property located?

Ms. Kim: Just north of Fairbanks, Alaska.

Ms. Travis: And Nick's property?

Ms. Kim: It's adjacent to my property, to the west of it. I can sketch it out for you. It won't be to

scale or anything, but it will give you an idea of what I'm talking about.

Yes. After my accident, I wanted to get out of New York and back to somewhere with

lots of nature. I created the colony in 2006 as a non-profit. It consists of 50 acres. To me, that's a

huge piece of property. An acre of land translates to about 75 percent of a football field. Imagine

that, times 50! When I bought it, it had 12 old cabins on it, built around 1900 to house the Carlo

family's ranch hands. I now use those 12 cabins to house a dozen musicians for two, three-month

periods, April-June and July-September. I never know how October will be weather-wise, so

sometimes I offer the second session the opportunity to stay on for an additional month. None of

us stay there in winter - it's too cold and too dark. I have a nice condo in Fairbanks where I live

November through late March. Heck, even Nick relocates into Fairbanks during the winters - he

doesn't open his resort up until May or June! I often hire people to do some routine maintenance

on the Birch Creek cabins and mess hall during February and March, but that really depends on

the weather. I also built a Birch Creek mess hall and a home for myself on the 50 acres, two

structures that are to the east and north of the 12 cabins.

Ms. Travis: So tell me a little more about how you have used the property between 2006 and the

present time. You mentioned renovations on the cabins. Can you describe that for me?

Ms. Kim: As you can imagine, the 12 cabins were in pretty rough shape when I bought the

property in 2006. This might be a good time for me to draw that map for you. Sorry, my left

handed drawing isn't so great, but I'll try.

When I bought the property in 2006, it had 12 one-room cabins on the western side of the 50

acres. They're grouped in three rows of four cabins. Each was built around 1900. Over the years,

before I bought the property, small bathrooms, electricity, and wood stoves were installed. I

imagine Nick's aunt and uncle did this when they started hosting those meetings. We get a lot of

snow, starting in December, and the roads can be pretty difficult to maneuver.

8 I spent about five months in 2006 renovating the 12 cabins to make them suitable for musicians

in-residence. I had my grand opening in September 2006 - I sent Nick and invitation but never

heard back. I chose September for the opening because it's one of the best times to see the

Aurora Borealis. We hosted a three-day grand opening retreat, which included campfire

chanting, sound baths, and lots of open-air yoga. I imagine he thought it was ridiculous.

Back to the renovations - when I bought the place, the cabins were in rough shape, but you could

use them year-round if you could get to them. I invested about $100,000 to renovate the 12

cabins for guests just after I bought the property. I tried to maintain the rustic look of the cabins

from the outside - I did some work on the chimneys, and patched a few holes in the siding, but

the majority of work was inside the cabins. I repainted all the interiors, refurbished the

bathrooms to include steam showers, and installed kitchenettes into each cabin so that our vegan

and gluten-free guests could make their own food, if desired. It was a ton of work, but the cabins

look amazing.

In 2012, you might recall, we had a particularly harsh winter. Eight of the cabins' roofs,

including three of the four that are the farthest west (the ones that Nick now claims as his),

suffered damage. I could not repair any of them until May. I'll label those damaged west side

cabins A, B, and C. I spent about $5000 to repair or replace the roofs on those three cabins alone.

I could not run the first session of the music colony in any of the eight damaged cabins that year.

I was able to reopen the cabins and invite eight more musicians to join the colony in August for

the second session.

In addition, shortly after I bought the property, I built a larger cabin on the eastern side of the

property for my own use. I had a local contractor build a simple one-bedroom home with a

kitchen and office. That cost about $70,000. I live there when the musicians are there, plus a bit

before they come and after they leave. It's too cold and snowy for me during the winter months,

so I relocate to Fairbanks. At the same time that I built my living quarters, I had the same

contractor build another structure on the eastern side of the property, for use as a communal

kitchen and mess hall for our guests. I've labeled those on the map, too.

Ms. Travis: So, just remind me, why have you contacted our firm?

Ms. Kim: Nick showed up at the Birch Creek Colony property in early June. He saw one of my

guests, Alec Mohammad, leaving one of the cabins and yelled at him. He used very harsh

language. Nick said that Alec was trespassing and had to get off the property. Alec explained that

he was my guest, was staying in the cabin, and that he had no desire or plan to leave. Alec

reported this to me right away. Then Nick wrote to me, I wrote to him, he wrote to me, and so

on. I brought a print-out of our email exchange.

Ms. Travis: Thank you. Had you ever seen Nick on your property at any time over the years?

Ms. Kim: Nick owns the Carlo Resort and Horse Ranch. It's basically a family camp where

families come and stay for a week, ride horses, fish in the stocked lake, etc. He runs it from May

or June each year through August. He charges these families thousands of dollars so they can

9 experience rustic living - I've heard he makes them cook their own dinner two nights a week! I

see Carlo on a horse, once or twice each summer, riding through the land surrounding the four

westernmost cabins on his way to the horse path that runs along the north part of my property.

Sometimes he is by himself and sometimes he is with a group of his guests. I never thought

anything of it. He's a neighbor, after all. I know that he rides and has horses and that he likes to

show his guests around. In addition, each year, I might see one or two of his ranch hands on

horseback riding through on Birch Creek property, including the land surrounding the four

western cabins. No big deal; I'm a friendly neighbor. Ha! A couple of years ago some of his

guests got lost and I found them wandering around the four cabins during a torrential downpour.

They were trying to get some shelter in the birch trees. I let them stay for dinner at the colony

and guided them back after the rain let up. Carlo sent me some berries as a thank you gift the

next day - he never said anything about the cabins then.

Ms. Travis: And what about this line of trees Nick mentioned in his email, and you just

mentioned?

Ms. Kim: That is just a line of beautiful birch trees. They look like they've been there forever.

Here, I'll draw it on the map.