assn 5-legal writing and research

From: Boss Partner

To: Valued Legal Analyst

Date: 04/17/YR01

Re: Smith v. Johnson

I guess you heard by now that we lost the motion to dismiss. Your help was

invaluable in preparing our motion and its accompanying papers. Unfortunately, the case

was assigned to that creep, Judge Haas. He cemented his reputation as a creep who hates

our law firm by ruling against us in spite of our superior arguments.

Now, obviously, we hope to win this case at trial or at least get a favorable

settlement. However, we have to face the realistic possibility that we may lose at trial.

Therefore, even now I want to start working on our appeal, just in case that becomes

necessary.

For the time being, I want you to start working on the jurisdictional issue. I really

think it's unfair for the California courts to assert personal jurisdiction over Jane, who had

never even been to California prior to this case and doesn't intentionally transact any

business in California.

Please read the section on jurisdiction in Judge Haas’ opinion and I want you to

prepare a counter argument that we could use in our appellate brief. I am not asking you

to prepare a full appellate brief (with tables of cases and issue statements and all that

stuff) and I am not asking you at this time to address any issue other than the issue of

jurisdiction.

So, please prepare a counter argument to Judge Haas’ ruling, explaining why

Haas has no idea what he's talking about and that the case should be dismissed. Please

make sure to address whatever arguments he made and counteract them with appropriate

case law of our own.

Thanks again!

B. Partner