PARALEGAL WAITING TO GET PAID

FACTUAL STATEMENT

1. January 20, 2007, (Plaintiff) was closing a loan for a client, she stated that a friend of hers, brother needed assistance in processing some important documents and had to meet a deadline before the cancel date, he had less than 30 days to complete the documents. (Plaintiff) gave client her business card and said if (Defendant) would like to retain her services she would be more than glad to assist him with the administrative process of preparing his documents.
2. February 12, 2007, (Defendant) called (Plaintiff) and stated that he needed help with completing some documents and of gathering receipts for reimbursement to submit before his deadline date and also needed some other papers notarized regarding several Power of Attorney and letters to be written. (Defendant) contracted (Plaintiff) services. (Plaintiff) processed letters, emailed and contacted (Defendants) clients or potential clients based on the information he dictated or correspondence he had from agencies and insurance companies that needed to be either filled out on forms or in writing. (Plaintiff) rode with (Defendant) in his vehicle to the five (5) locations for review and to do an analysis of those particulars, however (Defendant) was told by the SDAT that he needed to get a bond to protect himself and to handle the matter with each of the locations and to board and lock the buildings so that no one could get in. SDAT wanted to know who was processing the administrative documents for him, therefore, (Defendant) needed a letter from (Plaintiff); to submit to SDAT, (Plaintiff) gave Defendant) the number of Client Manager who now works at _________ , Maryland for him to retain a bond to which she provided for him.
3. While the process of reviewing calls to which (Defendant) was receiving from various real estate companies, there was a couple of companies Defendant) spoke with to which several letters were written (letters and Agreement of Purchase Sales Contract) and the talk of purchasing along with paper work of an Agreement of Purchase and Sale Contract was then ratified by both parties, however, (Defendant) jumped the gun on this and later felt uneasy and asked if (Plaintiff) could converse with the parties involved. (Plaintiff) then did research on this company and found that A and B of Investment Co.,were trying to pull a fast process on (Defendant) which would have cause great harm. (Plaintiff) stopped the process; the letters were written, reviewed by (Defendant) and emailed over to the parties involved, A and B Investment Co., these two individuals were trying to move in without going to settlement, start construction and auction the property off. (Defendant) was quite upset but very appreciative that (Plaintiff) stepped in and stopped the process. (Defendant) also received a call from another company (Defendant) submitted to them the information on the property, but never received a response thereafter.
4. October 2008, (Plaintiff) informed again that the administrative part have been completed and (Plaintiff) always submit an invoice, informed (Defendant) that the invoice is an agreed contract and needed to be paid. (Plaintiff) normally charge $25.00 per hour but since it was a large project, she made it an open invoice and reduced her fee to $18.50 per hour where (Plaintiff) would log daily work assignments on and decided to waiver the most recent dates for the invoice would be too much. (Defendant) took the invoice and stated that he will pay and it would take a little while before he is able to pay the invoice submitted to him. (Plaintiff) stated that the project was complete and that she really needed to be paid. (Plaintiff) kept reminding (Defendant) however, he kept saying to give him more time.
5. It seemed daily, (Plaintiff) got calls from (Defendant) for other work he needed. When (Plaintiff) could not make it on his schedule, he got distraught and (Plaintiff) would then see (Defendant) the next day at the earliest. Again it was either speaking with the (Defendants) clients because he did not know how to approach or speak in regards to what the matter maybe, it was as though (Defendant) thought (Plaintiff) was his personal assistant, but again he paid for small projects which was always invoiced. (Plaintiff) always had an invoice in hand or emailed one and would prepare one on (Defendants) computer system.
6. The Department of Environment submitted to (Defendant) a letter stating that his property is to be assessed for Lead Paint and there were forms and documentation that needed to be filled out and completed regarding such. (Defendant) again needed this project done and completed and asked Plaintiff) to contacted DOE to ask what it was they really needed; DOE stated that the property is residential, where (Defendant) stated that it is a family home and only family lived there and that there is no child at the age that was required for an inspection, however, DOE stated that the Land and Record Documents says otherwise. (Defendant) basically told DOE only family lives in Baltimore, MD when it is not true. The two seniors living there, who were placed in his hand by Social Services as to where they gave (Defendant) the power to manage their affairs so (Defendant) has the POA on them to where he manage their affairs daily. The to seniors told me that they are not related to (Defendant). So he lied to DOE. In finding and observing (Defendant) over the year, he is not the person (Plaintiff) met as a client; he is very deceiving and lies constantly on or about individuals.
7. Therefore, (Defendant) is managing a business not only assisting the two seniors but at least four others who do not reside at his address, where the (Defendant) drives to those locations and he has POA over them as well, (Defendant) collects their mail, manage these individual bank accounts, is to pay his clients bills and need letters written for his clients on various matters. Yet, (Defendant) is to be disabled himself and is receiving disability, to which (Plaintiff) just found out through the (Defendant).
8. (Defendant) has since got out of hand. (Defendant) also asked (Plaintiff) if she could help him in the process of completing paper work to have his home refinanced, but with the documentation and the information (Defendant) have to submit, the taxes he has is not good enough and his family will not co-sign for him.
9. July 2009 (Plaintiff) have since noticed that (Defendant) have taken vacations out-of-state, purchased several major items for his home, have had repairs done and (Plaintiff) wonders, he is spending happily, where is her pay. (Defendant) took one of his clients car owner because she is too old to drive it and isn’t able to walk. (Defendant) renewed the registration and tags for her car, he calls (Plaintiff)) and stated he needed (Plaintiff) to write a letter and would pick her up. (Defendant) drove everyone in his vehicle to owner of car house in the car with the (Defendant) was the two seniors and (Plaintiff). (Defendant), The two senior swere working to start owners car, they got it started and (Defendant) gave (Plaintiff) the keys and ask her to drive and follow him to Auto Zone, the battery wasn’t working well. Auto Zone put in a new battery, (Defendant) told (Plaintiff) to take the car home and run the car for him for a few days because the car owner neighbor was vandalizing her vehicle. (Plaintiff) parked the car at her address because it is hard to start and will stall. (Defendant) lied to car owner as to where her car was stating that it was in the shop, so when (Plaintiff) got wind of that deception, she stated when and where do she need to bring the car back, there is no insurance on (Plaintiff) driving it and the (Defendant) stated that he wanted (Plaintiff) to make payment on it since she had it parked at her location, (Plaintiff) said the car is not hers and basically it is sitting here in her driveway and she could charge for storage, (Defendant) told (Plaintiff) to just run the car and did not mention the insurance again. But, the truth of the matter was, since (Plaintiff) had no vehicle, (Defendant) wanted (Plaintiff) to run the owners car, (Plaintiff) just kept the car parked and would only drive it to (Defendant) when he needed her, but the big con was July 24, 2009 (Defendant) was again to take a trip out-of-town and asked (Plaintiff) if she could come to assist his clients, (go to his clients homes, shop, collect their mail, wash their laundry, cook and administer to one of the seniors his insulin until he returned), so the car was for (Plaintiff) to get around for (Defendant); this is where (Plaintiff) drew the line. (Plaintiff) could not believe (Defendant) asked her to assist with this, (Plaintiff) stated that she first don’t wash no one’s laundry but her own, and even though she is a diabetic, she is petrified of needles, (Plaintiff) stated that she is not a nurse and do not administer medication to anyone. (Plaintiff) told (Defendant) he needed to hire a nurse or someone, since he is managing his clients monies, (Defendant) got upset because (Plaintiff) told (Defendant) no. (Plaintiff) again asked for payment and needed to pay her rent, (Defendant) gives (Plaintiff) $200.00 and stated he needed an IOU, an IOU (Defendant) owes (Plaintiff) $1,853.52 and she stated that the $200.00 would be eaten up as interest accrual. (Plaintiff) (Defendant) the IOU (loan), it should be deducted or (Defendant) could have made arrangements to pay (Plaintiff) what he owes.
10. July 31, 2009, (Plaintiff) again demanded payment, (Defendant) got irritated drove to (Plaintiffs) home to get the owners car, because (Plaintiff) refuse to drive it and not have a way to get back home. But, since it seems (Defendant) is spending other people’s money and not paying his bills.
11. Defendants friend from time to time would stop by and saw that (Plaintiff) helped assist (Defendant) on the same project she assist with, (Defendant) used her to help him clean out some residence, had a yard sale, October 2007 and May 2008 and had his friend do the major work and did not compensate her the funds that she should have received, (Defendant) gave her $20.00 and said he would set her straight, she cleaned out and move out furniture from homes for (Defendant). His friend told (Defendant) he needed to pay (Plaintiff) and anyone who assisted him; he needed to pay their worth. His friend called and spoke with him regarding paying (Plaintiff) for the exceptional work she performed and if it wasn’t for (Plaintiff) helping him he would not have gained access of payment.
12. July 31, 2009 (Defendant) told her, to tell (Plaintiff) to again hold on. While, their conversation ended over the telephone (Defendant) did not hang up his call, he was still connected to his friend phone where she overheard him speaking to his sisters as to where his sisters stated, why haven’t you paid (Plaintiff) for her services and (Defendant) stated he is not compensating (Plaintiff), for her services.
13. August 5, 2009 (Plaintiff) again approached (Defendant) about payment he basically got angry and stated that he wasn’t paying.
14. Despite demands made for payment on more than several occasions payment has not been forthcoming.

Sue in small claims or regular court and file a Bar complaint as well!