The Good Lawyers

Contact Name and Title: Miranda ***, Atty
Contact Phone: 407***
Contact Email: ***@***.com
In response to the complaint filed by Ashley *** I will state that her narrative is a complete fabrication. I have only had Ashley's case for 11 months. I retrieved her file on August 3, 2018-she met me at the *** parking lot while in Orlando because she traveled from Tampa with her family. Her file consisted of roughly 300-400 pages of documents from another attorney which had to be reviewed (there is a fee for this). She had direct communication with me until I hired Madonna roughly 2 weeks after obtaining her file. There were instances when Ashley called or texted me instead of using the office number and I would inform Madonna to contact her to get her into the routine of calling the office first and only contacting me as a last resort. After which, Ashley would call my cell phone to get the office number off of my voicemail-there were several times when I returned her called and she said "oh I just called to get the office number, Madonna helped."

I further assert that Ashley texted me on December 21st stating that Madonna informed her that she was no longer with the office, and she asked for her file. I informed her that I had already replaced Madonna and that my new assistant would be starting after the holidays-we also transitioned into new office space in December. I do not recall apologizing to her for anything as there was nothing to apologize to her about. There was no break in communication and I did not owe Ashley an obligation to let her know the daily affairs of my office. However, all clients were contacted by my new assistant once she started. Moreover, there were no emails sent directly to me or calls placed to me during the period from Ashley that went unanswered. Any correspondence that Ashley has sent to me has been responded to for the exception of a few texts messages around the beginning of my representation when I was attempting to get her into the habit of calling the office.

Furthermore, I can verify that my office has had consistent communication with Ashley since we received her case. I am not obligated to keep her on notice of the daily operations of my office. The moment that Ashley found out that Madonna was no longer with me, she sent a text which was responded to the same day with a phone call. I have copies of text messages as well as a detailed log between my current assistant and Ashley. So the fact that she continuously states in her complaint that there were constant breaks in communication is a complete misrepresentation of the truth which is one of the reasons why I released her as a client.

Please also note that Ashley had a personal injury case, so there are usually no updates as long as the client is treating. Each time I tried to wrap up Ashley's case, she would go to a new doctor, further delaying our office from finalizing her claim. Ashley had the tendency to call us to tell us to send LOPs and crash reports to different doctor's offices that were not cleared by me. When we last spoke about wrapping up her case it was on or around March, so we started gathering the rest of her outstanding records and bills. Then we received a call from her in April requesting that we send a crash report to her via email and provided with information for another doctor. I refused to send a LOP to this provider.

Ashley called in May stating to my new assistant that she hadn't heard anything from "Miranda or her team in 6 months." I overheard this conversation and my assistant kindly reminded her that she had just spoken to her a few weeks ago and further went down the communication log. Ashley also threatened to come get her file-this was the final straw for me as I was preparing for maternity leave and just did not need the unnecessary stress from a client who is continuously and blatantly dishonest.

Ashley did call my office twice to speak to me after I informed my assistant to let her know that she would be receiving correspondence from me regarding the release of her file. I refused to talk to her via phone due to the fact that it has been clear that all communication with Ashley has to be documented because she has had the tendency to misrepresent the truth. I have sent emails to Ashley, which she has not responded to as well as sent communication to her address via certified mail which she has rejected. We never told her that her file was in the mail, but we sent correspondence requesting her to notify us of her new attorney's information so that we can forward her file accordingly. Ashley never did provide a new attorney but decided to make an appointment to retrieve her file. Ashley was charged $2,344.25 which included 7.15 attorney hours and 6.55 assistant hours.

It is unbeknownst to me as to why Ashley does not feel that I should get paid for my time. She now has over 500 pages of documents which were all reviewed by me. Additionally, my assistant has been paid for worked performed on her file. A lien has been placed on this claim. If this complaint is not withdrawn and my business suffers from this, I will be filing a law suit against Ashley *** for defamation of character. Attached are supporting documents which will negate all of Ashley's allegations.

Overall, Ashley *** has not been honest and forth coming about her experience at our firm. She has been very difficult and forced our office to only deal with her via written communication. Our records reflect that she continuously makes misrepresentations. What I do not appreciate is her making this bogus complaint as well as leaving long negative narratives on my FB page when she has several consistent complaints against her on her business page, *** which all state how she is rude and unprofessional. As a business owner, she should not make knowingly untrue damaging statements about another's person's business. Ashley is upset that I discontinued my representation of her case. I expect full payment and I reserve the right to sue her in civil court for any unpaid balance and will do so. I also intend to sue for defamation and intentional interference with a contract for the damage statements that were posted not only here, but on my company's facebook page.