RE: COMPLAINT LETTER
This letter serves as a formal complaint for your actions, which are fraudulent. The letter also contains demands for the redress of your actions failure to which further actions may be taken against you.
The pertinent facts that give rise to this Complaint Letter is that you held out to be a Licensed and insured Contractor. Accordingly, I obtained your services knowing that I was contracting with a legitimate individual. However, I later found that you were a fraud and that you were neither licensed nor held an insurance coverage. Further, you stole $6000 from me.
Your conduct perfectly meets the threshold for fraud. Under Florida law, the elements of fraud are: 1) a false statement of fact; 2) known by the defendant to be false when made; 3) made for the purpose of inducing plaintiff to act in reliance, 4) relied upon by the Plaintiff; and 5) resulting damage. Beagle v. Bagwell, 169 So.2d. 43 (Fla. 1st DCA 1964); W. Prosser, Handbook of the Law of Torts, Sec. 105 (4th ed., 1971). You stated that you were insured and licensed, yet you knew very well that you were lying. Besides, you made the false statements to induce me to contract with you. I honestly relied on your statement and ended up losing $6000.
For your actions as alleged herein, I seek redress in the following manner:
- THAT you refund and/or return my $6000,
- THAT we terminate the contract we entered for your services forthwith, and all our obligations in the said contract cease immediately.
If you do not comply with the above demands, I will be forced to pursue legal action, which would be detrimental to you. Also, please be made fully aware that if this action is taken, it will be done at your expense. To be quite clear on this issue, not only will the cost of hiring another contractor be applied to your account, but I will also hold you liable for any other costs we incur as a direct result of the delays and problems that your conduct caused.
Thank you for your prompt attention to this matter.
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