write a letter for my signature to our client, Kent Lugo. Please draft this correspondence to the client in business letter format. The letter will need a law firm letterhead (which you must create), date, address of client, Re: (regarding line) and salutation.

Because Mr. Lugo is the president of the local credit union in town, he should be addressed as President Lugo. In this letter, please do the following: 1. Begin the letter with "Attached to this correspondence, please find the Complaint, Interrogatories and Request for Production of Documents for your review." Then explain to the client what is going on. 2. Explain the time frames that the client is required by law to meet. Cite the Florida rule of civil procedure that tells you how many days the client has to respond to the Plaintiff's Complaint, then give the number of days. Tell the client what date the deadline is due. For example, "The Answer or Motion to Dismiss is due on or before DAY, DATE YEAR." 3. Ask the client to contact my paralegal (you) to set up a meeting with Attorney Higgins and to bring the following documents: (list necessary documents for the client.) 4. Ask the client to contact our office with any questions or concerns.

5. Draft a signature block for me. Include my name, title, Florida Bar number. 6. At the bottom of the page state "Enclosures" list them. This includes all documents you will enclose in the envelope with the letter. 7. Grammar and spelling count!

The Facts are these. We represent Triangle Credit Union who is the defendant in the instant case. Triangle Credit Union is located at 1516 Silver Star Rd in Orlando, Florida 32804 in Orange County. As you learned at Valencia College, business entities often have Registered Agents who received legal documents on their behalf. This is the situation in the instant case. Our law firm Higgins & Wiggins, LLC is the registered agent for TCU.

Yesterday, February 19, 2024, TCU was served (our law firm accepted service for TCU) a Complaint, Interrogatories and Request for Production of Documents. The Complaint is the initial pleading that starts a lawsuit. The other two documents are discovery requests that accompanied the Complaint when it was served on TCU yesterday.

Please draft a letter informing the President Lugo that TCU has been served by Plaintiff Maria Sanchez who is a client of TCU doing business with TCU. She tripped in the parking lot on October 16, 2023 at 9:30am. A very large oak tree whose roots had pushed up through the asphalt parking lot where she fell. Ms. Sanchez tripped over the piece of pavement and suffered injuries to her right wrist and right knee in excess of $50,000.00.

In the Client Letter make sure you include how much time is allowed to respond to each of the three documents you are sending to Mr. Lugo. Tell him how much time is allowed for each document and cite each rule that states the time limits. For each document, cite the rule and give him a date.

For example,

"According to Fla. R. Civ. P. ____, we have _____ days to respond to the Complaint. Therefore we will file an Answer or a Motion to Dismiss on or before_________." (MAKE SURE YOU LOOK AT THE TIME CALCULATION RULE!!!)

Now, for the Complaint, first look at Rule 1.140(a)(1) in the Florida Rules of Civil Procedure to find out how many days you will have to Answer the Plaintiff's Complaint. Second, find out how to calculate the number of days correctly. Do you count every day? Do you skip holidays? What about weekends? Third, Check your citation of the rule to make sure you have cited the Rule you are using correctly. Remember "Rule 9.800" in the picky and meticulous Appellate Attorneys' favorite Rules of Appellate Procedure?

Yep, look it up. Try looking at Fla. R. App. P. Rule 9.800(j)(1) to find the correct citation.

1. You will have to find the rule that tells you how long you have to respond to the Complaint. (Given above. You're welcome.) 1.140(a)(1) 2. You will have to find the rule that tells you how long you have to file the Defendant's Answers to Interrogatories. 3. You will have to find the rule that tells you how long you have to file the Defendant's Response to the Request for Production of Documents.

Then calculate the date of each item so you can put it in the client letter. Try looking in the Florida Rules of Civil Procedure in Rule 1.090 (1) Computation. It will send you to the Rules of General Practice and Judicial Administration. Remember what to do if you end up on a Saturday or a Sunday or a legal holiday.

Oh! And just to make it a bit more fair, see if you get extra time if the Interrogatories and the Request for Production of Documents are served at the same time as the Initial pleading (which is the Complaint.) Didn't they all come together in this case? Yes, they sure did!

Then check your citation of each rule. You know where proper citations are and you know why.

Fourth, the client needs to come in as soon as possible because time is running! We need the client to come in and bring any information that is pertinent to the case. What can you think of to ask for? Would pictures of the parking lot help? Of the tree and its roots? The injuries? What about any video of the parking lot? Any available reports or customer statements? How about insurance documents? Liability insurance? Did TCU do an Incident Report? Were there any witnesses? Did anyone help Ms. Sanchez? Make of list of items that President Lugo could bring that will help Attorney Higgins OR YOU respond to the documents that have been served upon the Plaintiff yesterday.

Fifth, draft the letter.

Along with the Letter to Client, you are also required to submit a Billing Log with 3 time entries. The format for the Billing Log is located in the Week 2 module.

You may need the following:

Fla. R. Civ. P. to find how many days to respond to each document;

Fla. R. Civ. P. Rule 1.090 (1) to figure out how to determine time calculations;

Fla. R. App. P. 9.800 to learn out how to cite rules; and

R. Regulating Fla. Bar.