Attorney at Law

3219 E. Camelback Rd. #181

Phoenix, AZ 85018
Phone: (602) 279-6933
Davis P. Bauer, Esq. Arizona Bar No. #035529
Licensed in Arizona, Colorado, Missouri, and Utah
davispbauer@gmail.com

IMMEDIATE ACTION DEMANDED

July 21, 2022
VIA EMAIL AND CERTIFIED MAIL
Northern Arizona Wind and Sun
3695 E. Industrial Dr.
Flagstaff, AZ 86004
david@solar-electric.com
andrew@solar-electric.com

RE: Demand for refund of defective equipment sold

To Whom It May Concern:
This letter is a demand for payment/refund for equipment sold by your company to my
client, Enock Nyamoti, and the only demand that you may receive before a lawsuit is filed against
you in Arizona court. If you have an attorney, please provide this letter immediately to them.
On or about February 2022, Mr. Nyamoti purchased solar and battery equipment for his
home, located at 6131 Day Road, Hartville, Missouri. From the time of installation up to the
present, the system never worked properly as advertised.
Although this is a unique system of products and equipment my client purchased, Mr.
Nyamoti made efforts to speak to representatives of Northern Arizona Wind and Sun on numerous
occasions, attempting to explain why the equipment did not work.
Although your company did try to troubleshoot the problems, no one was ever able to fix
any of the issues so that the equipment worked as it was intended. Essentially, Mr. Nyamoti wasted
his money on equipment that was defective. Mr. Nyamoti is now demanding a full refund of
monies paid for the defective and useless equipment.

1
Northern Arizona Wind and Sun
July 21, 2022
Page 2 of 2

He will also gladly return all the equipment he previously purchased to the company, as it
obviously is of no use to him now.
Demand

Due to the harm my client has already experienced, this letter shall serve as a pre-suit notice
demanding that you remit to my client the amount of $81,752.99 immediately, which can also be
made via physical check paid within 7 business days of receipt of this demand to:

Enock Nyamoti
6131 Day Road
Hartville, Missouri 65667

RULE 408 COMMUNICATION FOLLOWS:

My client is still amenable to negotiating this matter prior to any potential litigation with
you if you are of the belief that this issue can be fixed (i.e., sending out an engineer to my client’s
residence to attempt to fix the defective equipment). You can speak to me directly, or, in the
alternative, please have an attorney reach out to discuss this matter with me to avoid costly
litigation. Please do not contact my client unless you intend send out an engineer to fix the
equipment issues or to make alternative arrangements for the return of equipment and pay him
immediately.
We expect a prompt response to this communication within seven (7) days. If no response
or communication is received, then my client may pursue legal remedies for the damages.
Please contact me at the email address or phone number listed above with any questions.
This is the last written correspondence we will engage in over this issue before we potentially file
suit for damages against Northern Arizona Wind and Sun.

Very truly yours,

Davis P. Bauer, Esq.

DPB/ntb