You are on page 1of 2

Admitted in NY & NJ JOHN DOE, ESQ.

1 Broadway
Attorney at Law Suite 1008
New York, NY 10001
T: 212.555.1212
F: 646.555.1212
E: john@doe.doe

April 24, 2009

VIA REGULAR MAIL

Jane XYZ
1 Mains Street
Anytown, NY USA
Re: Able, Inc.
Dear Ms XYZ:

I am the attorney for Able, Inc. and its President Able Man. We are in receipt of your April 10,
2009 letter on behalf of Don Quest. We reject all of your demands listed in this letter because
Mr. Quest has no authority to take any actions against Able Man. Moreover, Mr. Man is not
only the majority shareholder of the corporation, but also its president.

Based on the information available to Able, Inc., it is clear that Don Quest is breaching his
fiduciary duty to the corporation. This conduct is in direct violation of the NYS Business
Corporation Law.

Even though Mr. Quest has repeatedly assured my clients that he has no intention of harming
Able, Inc. and its operations it has come to our attention that Mr. Quest continues to take actions
that are detrimental to the interests of Able, Inc. and its shareholders.

Most importantly, Mr. Quest is unjustly enriching himself at the expense of Able, Inc., and
breaching his fiduciary duty to the corporation and its shareholders.

Able, Inc., has been advised of its right to initiate a legal proceeding to seek an injunction
against Mr. Quest and to recover money damages from Mr. Quest. Able, Inc., reserves its right
to commence a lawsuit at the appropriate time. In such an action, Able, Inc., will seek an
injunction against Mr. Quest’s illegal actions and a sum of more than One Million Dollars
($1,000,000.00) along with legal fees, interest, costs, and disbursements.

Prior to taking such action, Aable, Inc., has asked us to contact you to see whether your client
will voluntarily cease and desist his illegal actions and resolve the issues between him and Able,
Inc. Accordingly, I ask you to contact me to discuss this matter no later than May 12, 2009. If I
do not hear from either you or Mr. Quest by that time, I will advise Able, Inc., accordingly.
Jane XYZ, Esq.
April 24, 2009
Page 2 of 2

This letter is not intended to constitute a full statement of all facts, rights or claims relating to
this matter, nor is it intended to be, nor should it be, construed as an admission of any kind or
nature, waiver, release or relinquishment of any rights or remedies available to Able, Inc.,
whether legal or equitable, all of which are hereby expressly reserved.

Sincerely

Vivek Suri

cc: Able Man, President, Able, Inc.