Thursday, June 11, 2009

Opening a litigation File on a Non Paying Client

On June 6, 2009 I did 27 notarizations in Springfield VA. The agreement was $5 per notary act plus travel ($25). The representative of the affluent wealthy civic association has refused to pay the $160 and there appears to be no administrative remedies. Consequently, the options are to bill each signer independently or litigate against the the unincorporated entity that does not appear to have an registered agent.
The first step after opening the litigation file is to document all communications and identify all parties and witnesses. After giving notice of the breach contract, one needs to thoroughly check the background from public records civil and criminal.Once the decision has been made to litigate, request for admissions, bill of complaint (warrant in debt) interrogatories, request for production of documents and possible depositions. Deposition sites need to be located. Modern technology is such that deposition can electronically recorded. Before one launches a litigation, one must be totally prepared with written briefs supporting your case. If I want to alert the media so the issue will receive appropriate coverage.Certainly, the smaller media outlets may have interest in a notary who did not get paid by wealthy Springfield Homeowners Association that will benefit thousands of dollars by a successful rezoning case.The bad news for the defendants is that I am GW trained legal assistant with extensive legal ability.