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WITHOUT PREJUDICE
Re: Sauron ats Baggins
Dear Mr. Crebain:
We acknowledge receipt of your letter and the Complaint
described therein, dated today’s date. Please note that
we have been authorized by our client to accept service
of this Complaint on his behalf, and hereby confirm
that we have done so, pursuant to the Rules. We advise
therefore that there is no need for your process servers
to pursue our client further, as service upon him personally
is not necessary in this regard. We trust that these
terms are acceptable to you.
Please be advised further that, for reasons of personal
security, compounded by your client’s efforts to compel
our client to release the disputed property to his representatives
against his will, our client has vacated his residence,
and is currently residing with companions who are known
to us, and that we are in direct contact with our client
for the purposes of this Litigation.
We also wish to inform you that, inasmuch as:
1. the Defendant is resident in the Judicial District
of Rivendell; and
2. the disputed property in question is held, and was
likewise obtained, and subsequently conveyed between
parties by means of various legally binding transactions
(the legitimacy of which your claim disputes), within
the Judicial District of Rivendell; and
3. our client has instructed us to proceed to Counter-Claim
against your client in this matter with respect to this
matter;
we have applied to the Superior Court of Justice in
the Judicial District of Rivendell to have this matter
adjudicated before the Court in Rivendell. We trust
that such application is satisfactory to you. In the
meantime, we have also filed a Notice of Postponement
in the District Court of the Principality of Mordor,
in order to delay procedure of this action, subject
to the Ruling of the Superior Court of in the Judicial
District of Rivendell as to the issue of juris prudence
in this regard.
We enclose a copies of the Notice of Postponement, the
Notice to Defend and Counter-Claim, plus the Application
to the Superior Court of Justice for adjudication of
this matter before the Court.
Please note that, in our Notice of Defense and Counter-Claim,
we have asked the Court to dismiss all of your client’s
claims outright, pursuant to the matters of Statute
as described in my earlier letters to you, and the issues
of legal ownership as set down in case law and supported
by the affidavits of Messrs. Gollum and Baggins. We
also enclose copies of the affidavits of Messrs. Gandalf
and Elrond, relating to the incident of the alleged
robbery of your client, further disputing your client’s
claim of rightful ownership.
We advise that we have also asked the Court to levy
extensive punitive damages against your client for the
wrongful, willful and malicious pursuit of this claim,
as well as punitive damages claim for psychological
“pain and suffering” brought upon our client by your
client’s representatives, and fees and costs on a solicitor/client
basis.
Please also note that, under the Rules of Civil Procedure,
you have 45 days to respond to this Notice to Defend
and Counter-Claim, after which a summary judgment will
be issued by the Court against your client, in absentia.
We trust that the foregoing is satisfactory to you,
and remain,
Yours faithfully,
Dewey Cheatem & Howe
Barristers and Solicitors
per:
I.M. Cheatem, Q.C.