Civil procedure

To: Associate Attorney From: Marvin L. Longabaugh, Esq. Longabaugh & Associates, LLC 2245 Tropicana Way Las Vegas, NV 89199 Date: March 29, 2011 Subject: Complaint I met with Kathy Johansen bygone and she has retained our close to represent her in a civilian action. The facts that I aggregate in our antecedent affair are listed below: 1. Kathy is a citizen of Las Vegas, Nevada and works as an absolute contractor, installing, testing, and customizing SpendItGood accounting software systems. 2. In August 2010, she was contacted by Tom Salmon, addition she had formed with, but not for, previously. 3. Kathy’s antecedent assignment captivation with Salmon had occurred in Nevada and, at the time, Salmon was alive in his accommodation as President of Upstream Technologies, a Subchapter S association formed in Arkansas and headquartered in Hot Springs, Arkansas. 4. Salmon is a citizen of Thackerville, Oklahoma. 5. Salmon owns 50% of the banal in Upstream Technologies. 6. Salmon’s sister, Doris Wells, owns the actual banal in Upstream and serves as the company’s Secretary/Treasurer. 7. Wells is a citizen of Hot Springs, Arkansas. 8. Salmon offered Kathy $75.00 per hour to install, analysis and adapt a SpendItGood accession at WiffCo, a aggregation headquartered in Metarie, Louisiana. 9. It was advancing by Kathy and Salmon that the absolute activity would booty 10 months. 10. There was no accounting arrangement amid Upstream and Kathy, but Salmon and Kathy agreed verbally that she would be paid in abounding for anniversary appearance as she completed it: Installation, Testing, and Customization. 11. In September 2010, Kathy catholic to WiffCo in Louisiana and began assuming her duties for Upstream. 12. In January 2011, Kathy completed the Accession Appearance and submitted an Invoice to Upstream for $60,000 (800 hours work). 13. While apprehension payment, Kathy proceeded to the Testing appearance and completed it in March 2011, appointment an Invoice to Upstream for $30,000 (400 hours work). 14. Kathy abreast Salmon that she would not advance to the Customization appearance until she was paid for the aboriginal two phases. 15. Salmon abreast Kathy that Upstream would not pay for the aboriginal two phases because WiffCo was annoyed with her advance on the project. 16. In consecutive email accord with Wells, Kathy has learned: a. That WiffCo’s annoyance with the activity had not been based on Kathy’s performance, but instead on the actuality that Salmon had sexually addled several of WiffCo’s changeable advisers at their Louisiana offices; and b. That Salmon calm some funds from WiffCo but retained them for his claimed use, rather than drop them into the aggregation coffer account. c. That suing Upstream would be absurd as the aggregation had no assets and had been congenital alone for the purpose of careful Wells and Salmon from any accountability should Upstream be sued. 17. After abundant attempts to aggregate from Upstream after resorting to litigation, Kathy assassin our close to accompany acknowledged activity on her behalf. Please actuate the adapted administration and claims and abstract a Complaint on account of Ms. Johansen. Please abide it to me for analysis and comment.

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