John Goins
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Andrew Mintez
Roemer & Harnik LLP
45-025 Manitou Drive
Indian Wells, CA 92210
Phone: (760) 360-2400
Fax: (760) 360-1211
Dear Sir,
Re: NOTICE OF INTENTION TO PROCEED WITH LITIGATION
Reference is made to Case No. PSC1803464 filed at the Superior Court of the State of California, in and for the County of Riverside – Palm Springs Courthouse. You informed me that you will be filing a demurrer because your client is not liable for any of the causes of action in the foregoing lawsuit.
I wish to reiterate that Insert Name of Client is liable for misappropriation of trade secrets pursuant to Cal. Civ. Code § 3426 et. seq. and Cal. Bus. & Prof. Code § 16607; tortious interference with contractual relations, intentional interference with prospective economic advantage; negligent interference with prospective economic advantage; violation of unfair competition pursuant to Cal. Bus. & Prof. Code § 17200; California Statutory False Advertising pursuant to Cal. Bus. & Prof. Code § 17500; conversion; as well as fraud and misrepresentation. I will seek damages for all the foregoing causes of action.
Apart from litigation, I have no other way of obtaining redress for the damage that your client has caused me through her acts and omissions.
I also intend to pursue attorney fees, pre and post judgment interests, and costs of this suit as allowed by law. If you wish to discuss anything in regard to this case, please contact me using the information provided above.
Yours Sincerely,
___________________________________
John Goins
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