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CHAPTER 35

Preliminary Objections

Jones Seeks a Way Out

THE DRAFTING REQUEST

MEMORANDUM

TO: Phillip Torres

FROM: Don Philbrook

RE: Arlen Jones Construction Case

DATE: January 21, 2012

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I represent Arlen Jones, a neighbor of mine who is in the excavation business. He has just been served with process in a federal court suit down in Boston, arising out of some work he did on a house over in Alton. I have attached the original complaint in the action and the third-party complaint against Jones. He is surprised and puzzled by the suit, since he thought the job went fine and the owner was happy. He is also concerned about defending an action down in Boston. Arlen is a local guy with a small business; he is hardly in a position to pay big city legal fees. (I'm not even sure he'll be able to manage mine . . . I'll probably have to put in a pool so he can pay me off by doing the excavation!)

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