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Andrea, Esq.
Andrea, Esq., Attorney
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Experience:  25 yrs. experience in family law, estates, real estate, business law, criminal defense, immigration, and employment law.
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Here is an excerpt from a Complaint I plan to file, pro se,

Customer Question

Here is an excerpt from a Complaint I plan to file, pro se, in district court that explains what is going on:

1. Plaintiff, as a United Food and Commercial Workers Union Local 400 (Local 400) member, brings this action in order to gain access to certain records and accounts necessary to verify information contained within Local 400's 2011 LM-2 and 2012 LM-2 in accordance with the Labor Management Reporting Disclosure Act of 1959 (LMRDA), 29 U.S.C. Sec. 431(c).
2. The United Food and Commercial Workers Union International (UFCW International), the parent body of Local 400, carried out an investigation of alleged misconduct that took place during Local 400's 2012 election. This investigation found that the allegations of misconduct had merit, and UFCW International suspended the results of the 2012 election and called for a new election.
3. The results of UFCW International's investigation raise concern about the conduct of Local 400's officers and/or employees and how Local 400's resources were managed in general and especially during the 2012 election campaign.
4. A variety of disbursements and other information contained in Local 400's 2011 LM-2 and 2012 LM-2 seem disproportionate or inconsistent compared with information reported in previous years or information reported on Local 400's website.
5. Plaintiff has requested access to records and accounts relating to disbursements that could be associated with Local 400's 2012 election and the unusual disbursements mentioned in paragraph 4 in order to verify the accuracy of information contained within Local 400's 2011 LM-2 and 2012 LM-2. Local 400 has not responded to these requests.


I can't afford to hire an attorney to represent me, but I am hoping to find someone that can look over my Complaint (its only 7 pages) and provide some feedback.
Submitted: 10 months ago.
Category: Legal
Expert:  Andrea, Esq. replied 10 months ago.

Dear Customer, My name is XXXXX XXXXX my goal is to provide you with Excellent Service, I am a Licensed, Practicing Attorney and would like to help. The Rules of Civil Procedure prescribe a certain format for pleadings filed with the Court, including Complaints and, if the pleading which the litigant wants to file does not conform to this format, it will be returned without being filed. You will come to learn that Judges are fairly lazy and they have to have the facts literally, hit them in the face. I understand what you are trying to say, and it is pretty close to the format, but not quite what the Rules prescribe. Your Complaint needs to be revised to conform to the format and I would like to help, but it will take some time, and could not be accomplished for the twenty dollar value placed on your question. We are not permitted to discuss or negotiate values with customers, but if the customer wants this type of individualized work, they offer a bonus amount and if it is acceptable to the expert, the customer deposits that amount with JustAnswer and when the expert completes the revision, part of that amount is paid to the expert and part is kept by JustAnswer. The revised Complaint would be ready for you in about 90 or so minutes.

 

Below, is an example of what the revision will look like. Your Paragraph one as well as some of the other paragraphs you included in your facts would have to be divided into more than one paragraph in order to meet the formatting requirements.

 

You wrote,

 

 

"1. Plaintiff, as a United Food and Commercial Workers Union Local 400 (Local 400) member, brings this action in order to gain access to certain records and accounts necessary to verify information contained within Local 400's 2011 LM-2 and 2012 LM-2 in accordance with the Labor Management Reporting Disclosure Act of 1959 (LMRDA), 29 U.S.C. Sec. 431(c)."

 

Revision:

 

1. Plaintiff is (Your Name) , residing at _______________ , _______________ County, State of Maryland.

 

2. Plaintiff is a member in good standing of the United Food and Commercial Workers Union, Local 400 (hereinafter, the "UNION") which has an office located at _________________ , ______________ County, State of Maryland.

 

3. The Labor Management Reporting Disclosure Act of 1959 ( (hereinafter, "LMRDA"), 29 U.S.C. Sec. 431(c) provides, inter alia, that access to records and accounts be made available to members of said Union.

 

 

I do not know what "LM-2's" is, therefore, I could not incorporate it in the example I was giving you. "LM-2's" would need to be explained in a separately numbered paragraph. In any event, you understand what I am trying to show you in the example and how the Complaint would be revised,

 

________________________________________________________________________

 

 

Please be kind enough to rate "Excellent Service" so that I receive credit

for assisting you,

 

 

Bonus and Positive Feedback on survey is very much appreciated,

 

 

ANDREA

 

 

 

Customer: replied 10 months ago.

Gotcha. These paragraphs were my "Preliminary Statement." The rest of the Complaint is "broken down" more where each paragraph makes only one point more or less. Do I have to "break" each paragraph down into just one point for the "Preliminary Statement" as well?

 

I'm new to this site, and I don't know how to do bonuses. But if I can't figure it out, I'll just write out another question and "address" it to you (or I'll wait until I see you online to ask the question-I'm not in a rush). I'm going to make as many changes as I can first, that way you'll hopefully answer my question for a small(er) amount of money. (I'm just a poor union worker seeking justice, lol!)

 

BTW, LM-2 is the union's Annual Report.

Expert:  Andrea, Esq. replied 10 months ago.

Hi, Dan, Thank you for your reply,

 

I don't quite know what you mean by "preliminary statement" because the Complaint is not divided that way. If a Plaintiff is asserting more than one basis for relief, the Complaint is divided into "counts", i.e. Count I, Count II, Count III and so on. In Answer to your question, each numbered paragraph should contain only one statement. You should also assume that the person reading your Complaint does not know anything about your case or your situation, just like I did not know what LM-2's were. To explain how the site works, a customer places a deposit with JustAnswer, asks a question, receives an Answer; if there is something in the Answer which the customer does not understand, he may ask a follow up question for clarification at no additional charge, then gives the Expert a rating because that is the only way the Expert will receive credit for assisting the customer. If the customer does not rate the Expert, then he/she does not receive any credit for assisting the customer. I have not been on the other side of the screen, but this is how it was explained to me - When the customer rates the Expert, the customer's screen shows a message, asking if he wants to leave a bonus for the Expert. The bonus is deposited with JustAnswer which gives part of it to the Expert and takes the rest. You did not see that message because you did not rate the Answer I gave you and it only comes up when you rate the Expert's service to you. Please let me know if you will want assistance in revising your Complaint, or if you will handle it on your own, but in the meantime, please rate my service to you so that I receive credit for the Answers and information I furnished you, otherwise I will not get any credit for assisting you. Thank you for understanding,

______________________________________________________________________

 

 

Please be kind enough to rate "Excellent Service" so that I receive credit

for assisting you,

 

 

Bonus and Positive Feedback on survey is very much appreciated,

 

 

ANDREA

 

 

Andrea, Esq., Attorney
Category: Legal
Satisfied Customers: 11259
Experience: 25 yrs. experience in family law, estates, real estate, business law, criminal defense, immigration, and employment law.
Andrea, Esq. and 4 other Legal Specialists are ready to help you
Expert:  Andrea, Esq. replied 10 months ago.

Hi, Daniel, Thank you for the "Excellent Service" rating, I appreciate it, If you have any further questions on drafting your Complaint, or any questions in the future, please feel free to ask for me by typing my name at the beginning of your question, like this,

 

 

"For Andrea .........."

 

 

Thank you once again for allowing me the opportunity to be of assistance,

 

 

ANDREA

 

 

 

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