nts, stocks, etc., but owns only personal items exempt from execution under the laws of our state, then any judgment you obtain may not be worth much.

negatives to lawsuit

besides the fact that you may lose a lawsuit against ms. ** or that any judgment obtained may be uncollectible, there are other negative factors you should consider before bringing a lawsuit. these include court costs and attorney fees. court costs are recoverable, but other costs, such as travel, the time lost when you are called to testify （or required to help us develop the case）, and attorney fees, are not recoverable.

my services

i am familiar with the nature of your manufacturing business and am qualified to represent you in this matter if you choose to proceed. my fee would be based on my normal hourly charge of $250 for myself and $150 for associates. trial time is billed at $1,000 per day. the initial services of preparing a complaint and serving same would cost approximately $300. preparing a request for an injunction and attending a hearing on the injunction would cost approximately $2,500.

it is quite possible that ms. ** would not retain her own counsel and not answer the complaint. this means that a default judgment could be taken without the necessity of a trial. here attorney fees would probably amount to no more than $1,000.

i require a $1,000 retainer to open a file and commence an action.

if you wish to proceed with this matter, i will need to know the full names and addresses of your customers to whom ms. ** is presently selling and the estimated sales volume which you have lost.

if you have any questions, please call me.

very truly yours,

name of attorney

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