Thomas Boysen lives in Orlando, Orange County, Florida. On July 3rd of this year, he took his sick goldendoodle, Scout, to the Crazy Tails Pet Clinic in Orlando, Florida, for treatment. Thomas was told that Scout was seriously ill and needed his spleen removed immediately. Thomas pre-paid $1,500.00 on his credit card for the dog's surgery, left Scout at the clinic, and went to work. Several hours later, Thomas received a call at work from Crazy Tails Pet Clinic stating that the surgery had not been done because there was not a surgeon available to do it. Thomas left work, picked Scout up, and brought him to another pet clinic in Orlando. That clinic told Thomas it was too late to save Scout. Unfortunately, after hours of being ignored at Crazy Tails Pet Clinic, Scout had to be euthanized. Although the Crazy Tails Pet Clinic refunded the $1,500.00 for the surgery it did not perform, Thomas was still charged $300.00 for the visit to Crazy Tails Pet Clinic. Thomas also lost $450.00 in wages from having to leave work early on July 3, and being unable to go to work on July 4 and July 5. (He was so distraught he found himself continually breaking down in tears and could not function at work.) Thomas had to pay an additional $400.00 to the second pet clinic to diagnose and euthanize Scout. Scout was a purebred goldendoodle. Thomas purchased Scout from a breeder six years ago for $1,800.00 after his wife died. Thomas has told several witnesses over the years that if it weren't for Scout, he doesn't know how he would have survived the loss of his wife and love of his life.

Thomas is hopping mad at the Crazy Tails Pet Clinic. Thomas loved Scout like a true fur baby. He was sobbing in your office as he angrily retold the events leading up to Scout's death. Thomas has clearly stated to you that he doesn't care how much it costs, he wants to "sue the pants off" Crazy Tails Pet Clinic for damages. He is clearly emotionally distressed at the loss of his best friend. There is no doubt in your mind about the depth and breadth of his loss. You assured Thomas you would research the issues, and file a lawsuit against Crazy Tails Pet Clinic.

1. Draft a Complaint for all applicable causes of action against Crazy Tails Pet Clinic.

a. Make sure to select the correct court and include a case style/caption,

b. Include your jurisdictional and venue allegations,

c. State the elements of your cause(s) of action against Crazy Tails Pet Clinic and provide the factual allegations.

Compose a short and plain statement of the claim. Do not make legal arguments. State as briefly as possible the facts showing that each plaintiff is entitled to the damages or other relief sought. State how each defendant was involved and what each defendant did that caused the plaintiff harm or violated the plaintiff's rights, including the dates and places of that involvement or conduct. If more than one claim is asserted, number each claim and compose a short and plain statement of each claim in a separate paragraph.

d. State your claim for relief detailing the damages.

State briefly and precisely what damages or other relief the plaintiff asks the court to order. Do not make legal arguments. Include any basis for claiming that the wrongs alleged are continuing at the present time. Include the amounts of any actual damages claimed for the acts alleged and the basis for these amounts. Include any punitive or exemplary damages claimed, the amounts, and the reasons you claim you are entitled to actual or punitive money damages.

e. You may make up a name, address, bar number, etc. for the attorney signature block.

2. Draft a letter to your client who resides at 6789 Feline Drive, Orlando, FL 32800. In the letter you should explain to him the cause(s) of action that is/are and potential damages that are recoverable arising out of this incident, as well as transmitting a copy of the proposed Complaint. Give him clear direction as to what you would like him to do. In this case, you want him to review your correspondence and the proposed Complaint and respond to you in writing with authority for you to file it on his behalf. If he has any questions about it, he should contact you before giving you authority to file it.