l3r\l)K()l I\ :I I I

~'~In

JC

D \ 1) l\ l l1~I-l l~. I .I ~P
1

10 66 ilsl1ire Blvd.~ St . 400

Lo " ngeles, California 90024
(310) 598-8448 (t) (310) 598- 8486 (t)

M. fl~lkmthdt
h<fllfM:1m

In~

Pc) man

l>itdm~br

Pe~man

h~Jp . i:otu

8r.am.lt1n K. ltn.a
Brandon'".p bdlJp.com

SOLTCTTATTO"'J

2015

Dear

r.

In our revie\v of civil cases recently fi1ed in Los Angeles & Orange Countv. \Ve discovered that, on
2015 ..
filed a la\A/Suit in the Orange County Superior Court against
TI1e la\vsuit alleges
various causes of action including Emplo)'n1ent sexual harassment and battery. On multiple occasions
defendant lured plaintiff to a hotel roorn~ ripped her clothes off and forcibly digitally penetrated her. On separate
occasions he \Vould tear at her clothing and force her to masturbate him. Defendant threatened to fire plaintiff if
she refused his sexual advances ..
Please note that ) 'Ou ha e a very limited time (approxjmately 30 da:ys) from the tirne you are served with the
sun11nons and complaint to ans\ver or othen\ise respond to this complaint. Our firm has substantial expertise in
handling lltigation of this kind and \Ve \vou1d 1ike to offer our firm s services and expertise to assist )OU in
responding and defending this lawsuit. You may ha e received con1munication from other la\v firms regarding
this lawsuit. Please bear in tnind that \vhile \Ve offer the same high quality of legal representation as other firms,
in all likelihood, you \viii find our rates to be more reasonable.
In order to keep all your options open with respect to this case, \Ve urge you to promptl)' intervie\.v and retain the
attorneys that \ ill be representing ) 'OU. Under the California Code of Civil Procedure: there are a number of
strategic 1neasures available to a defendant in a la\.vsuit which need to be taken advantage of quickly. For
example . California discovery 1a~'s and guidelines p~ohibit a plaintiff in an action frotn serving discovery until
20 days after the crvice of summons and complaint on the defendant. On the ether hand defendant in a la uit
need not \Vait before serving its discovery on plaintiff. Although this strategy may not be advisable in all
circun1stance ~ it gi es a vigilant defendant the opportun it)' to be the first party to compel testimony of the
plaintiff and/or third parties.
Based on the infonnation \Ve have so far; \i e strongly feel that our firm can be of a istance to you. We \VOuld
like to discu s this 1natter further with you to determine if in fact \.Ve can help )OU with this case and to afford
you the opportunity to evaluate us and decide if \Ve are the right fit for you. Please contact our offices, at (310)
598-8448, at your earliest convenience so that \Ve can discuss your case. Of course . ) 'Otl will not be charged for
this initial consultation and you have no obligation to retain our firm.

Sincere1y,

Reference Number: