1. Erica V. Unit 5 1
Law Offices of Alice Black
2100 Main Street
Friendly, New Washington 00065
(200)-267-7000 FAX 267-7001 www.ThomasLaw.com
May 2, 2015
Inki Appliances Company
1001 Maple Drive,
Friendly, New Washington 00065
Re: Property: Inki Microwave
Demand: Full replacement, or the cost thereof
Dear Mr. Spear,
My client, Mrs. Tatum, purchased a microwave from your company, Inki Appliances.
Three days after having the microwave in possession, the microwave malfunctioned.
My client returned to the company for a repair or replacement of the microwave,
but was refused a repair or replacement.
There was no written or oral contract at the time of sale; however, section 50-102-
314 of New Washington statues provides that “a warranty that the goods shall be
merchantable is implied… if the seller is a merchant with respect to the goods of that
kind.” We demand that you provide a replacement, or the cost thereof. In the event
that Inki Appliances denies the replacement, or the cost thereof, we will have no
other choice but to file a claim.
Smith V. Appliance City, 56 N. Wash. 162, 868 N.E. 997 (1995) provides, a seller has
three options when they breach an implied warranty: return the purchase price to
the buyer, repair the merchandise, or replace the merchandise.
Because of your negligence, my client has had to go without the use of a microwave,
been forced to seek legal help, and has been otherwise inconvenienced. The purpose of
this letter is to invite you to promptly address a warranty claim and demand that your
replace the microwave.
Thank you for your time and attention to this matter. I look forward to working with you
in coming to an amicable resolution in the very near future.
Very truly yours,
Alice Black
Attorney at Law

2. Law Offices of Alice Black
2100 Main Street
Friendly, New Washington 00065
(200)-267-7000
FAX 267-7001
www.ThomasLaw.com
May 2, 2015
Via Facsimile and U.S. Mail
Holly Dixon
Re: Dixon v. Cary
Probate of holographic will
Dear Dixon,
After completing substantial research about the holographic will, I have come to the
conclusion that the holographic will is most likely not eligible for probate. According to
statutory law: Tex. Prob. Code. Ann. Section 59, Requisites of a Will (Vernon 1980),
provides: “Every last will and testament…. Shall be in writing… and shall, if not wholly
in the handwriting of the testator, be attested by two (2) or more credible witnesses…”
Unfortunately in this case, the holographic will was partially in the testator’s handwriting,
partially typed, and there were no witnesses.
Also, Tex. Prob. Code. Ann. Section 60, Exception Pertaining to Holographic Wills
(Vernon 1980), provides: “Where the will is written wholly in the handwriting of the
testator, the attestation of the subscribing witness may be dispensed with. Such a will
may be made self-proved at any time during the testator’s lifetime by the attachment of
annexation thereto of an affidavit by the testator to the effect that the instrument is his last
will; that he was at least eighteen years of age when he executed it…; that he was of
sound mind; and that he has not revoked such instrument.”
Providing these two Statutory Law, my opinion is the holographic will is not eligible for
probate. Providing that none of the requirements have been meet for either statute. In
one, we needed two witnesses, which we do not have. In the other, the will had to be
wholly in the testator’s handwriting, which it is not.
Sincerely,
Alice Black
Attorney at Law

3. Erica V. Unit 5 3
Law Offices of Alice Black
2100 Main Street
Friendly, New Washington 00065
(200)-267-7000 FAX 267-7001 www.ThomasLaw.com
National Insurance Company
459 Twenty-Second Street,
Friendly, New Washington 00065
Re: Persons insured under policy
The purpose of his letter is to inform you of the status of your case and to summarize the
law in regard to the insurance policy.
As you know, this case is for the concern of National’s duty to defend persons it insures
under its automobile insurance policy. There is no statutory law governing an insurance
company’s duty to defend its insured, however, there are relevant cases.
Wrickles v. Washington Ins. Co., 61 N. Wash. 104 (Ct. App. 2007). Where it is
determined that the insurer has unjustifiably failed to defend against claims against its
insured, the insurer is liable for any judgment entered against its insured. In addition, the
insurer may be liable for any reasonable settlement entered into by the insured.
State Farm Ins. Co. v. Peterson, 56 N. Wash. 38 (1995). The obligation to defend arises
out of and must be found in the insuring agreement promising to defend the insured
against liability. This states that you are obligated to defend the insurer as long as it is
within the agreement of the policy.
Alison v. Lincoln Ins. Co., 60 N. Wash 677 (Ct. App. 2000). The duty to defend is
triggered when an injured party’s complaint against the inured states facts that bring the
case within the coverage of the policy. You are obligated to defend the insured when and
if the complaint is within the policy.
Jamison v. Lincoln Ins. Co., 58 N. Wash. 430 (1998). An insurance company may refuse
to defend its insured only when the allegations in the complaint are completely outside
the insurance policy coverage. You are not obligated to defend the insured when the
allegations are no where near the policy statements or agreements.
Wilson v. Washington Ins. Co., 59 N. Wash. 980 (1999). If the allegations in the
complaint against the insured may fall within the coverage of the policy but are
potentially excluded by any noncoverage provision in the policy, then the insurer is under
a duty to defend the insured in the primary action. The duty continues until a court having
jurisdiction over the case finds that the insurer is relieved of the liability under the
noncoverage provisions of the policy. This means you are obligated to defend the insured
if the allegations fall within the coverage of policy, but only the primary action. Any
other actions that are excluded by noncoverage provision of the policy can be relieved of
liability.

4. National Insurance is obligated to defend the insured party anytime the allegations are
within the policy agreement. The only time National Insurance is not liable is when any
allegation is completely outside of the policy coverage, and when the allegation is
excluded by any noncoverage provision in the policy.
Truly Yours,
Paralegal
References:
Goguen, D. (2015). Demand Letters: The Basics Settling. Nolo; your dispute may be as
easy as writing a payment demand letter. Retrieved from http://www.nolo.com/legal-
encyclopedia/demand-letter-settle-dispute-30105.html
Practical Law, (2015). A thomas reuters legal situation; legal opinion. Retrieved from
http://uk.practicallaw.com/1-200-1399#
Putman, W. (2014): APC The legal analysis and writing, 4th Ed.