Reference no: EM133304605
CASE: Draft a complaint for your client, Bill Blair Auto Repair, Ltd. in response to the complaint document provided below based on the date listed on behalf of Plaintiff Sam Adams.
Please make sure to respond to each numbered paragraph of Plaintiff Sam Adams' complaint with a similarly numbered paragraph subject to the requirements of Federal Rule of Civil Procedure 8. Please also make sure to include an affirmative defenses section in the answer with any and all affirmative defenses that you think may be appropriate.
Your interview with Bill Blair provides that your client agrees with the following facts:
Blair Repair is a Georgia Corporation with its principal place of business in River City, Georgia.
- Blair Repair frequently advertises its services to Columbia residents.
- Blair Repair represents itself as a classic automobile repair shop, doing business as "Bill Blair Auto Classic Repair Shop."
- Mr. Adams took his Porsche to Blair Repair for repair work.
- Blair Repair accepted the request to repair Mr. Adams' Porsche.
- Mr. Adams left his Porsche in the care of Blair Repair in order for the repair work to be completed.
- Blair Repair tendered a service order form regarding its repair work on Mr. Adams' Porsche.
- Blair Repair's service order form indicated that: a) A leak in the Porsche's gas line had been repaired; and b) Seven feet of the Porsche's gas line had been replaced and "clamped."
- Mr. Adams tendered $551.65 to Blair Repair for full and complete payment of the repair work that Blair Repair performed on the Porsche.
- At no time either before or after Defendant Blair Repair engaged in the repair of the Porsche, did Blair Repair warn Mr. Adams that the repair work was otherwise incomplete or faulty.
Bill Blair, however, explained that it was his understanding that Blair Repair verbally warned Mr. Adams that it would have been prudent to replace all fuel lines in the Porsche at the time of repair. Bill Blair also maintains that his shop did nothing wrong and that a number of different things might have caused the fire.
Bill Blair did not have sufficient information to confirm the other factual allegations in the complaint.
Bill Blair wishes to aggressively oppose the complaint and maintain all defenses that his shop might have against the claims made by Plaintiff Sam Adams.
Question: Draft a complaint for your client, Bill Blair Auto Repair, Ltd.?