Randolph and Kothari

Attorneys at Law
450 Pointe Place, Arlesdale, IL
Atty. Puruda Kothari
February 5, 2016
Ted and Martha Reubens
329 North Oak Lane
Arlesdale, IL 69878
RE: Claim against Vivian Andover
Dear Mr. and Mrs. Reubens:
As you may be aware, I met with the counsels for Mrs. Vivian Andover on February 1st to
talk about a potential settlement. I am writing to explain the settlement terms in detail as offered
by Mrs. Andovers counsel in return for your dropping the lawsuit against her. This is a sound
offer hence, I recommend that you accept it for the reasons explained below.
Mrs. Andover offered $2200 upfront with an additional $2000 contingent to surgery
being performed upon Billy. She has also asked us to drop the insurance claim against her. Her
only concern is this transaction being completely confidential. She feels that her goodwill in the
community was affected after Billy being injured on her premises, and if the neighbors were to
know that she paid a substantial sum towards his treatment, this would fortify their resentment
towards her. We agreed to comply with this condition since you also previously mentioned that
your interest lies in mending the relationship with her in the best way possible. Additionally,
being aware of your financial concerns regarding Billys ongoing education, this offer will take
care of that aspect immediately.
Mrs. Andover wants Mr. Reubens to resume the yard work on her premises, as well as for
Billy to continue playing in her yard. We were able to make her counsels understand that this will
not be a possibility as long as she continues to harbor stray animals on her property. Hence, it
was agreed upon that she will not allow any strays, or pests of any kind on her premises.
However, despite our insistence, Mrs. Andovers counsels maintained that she will continue to
feed birds and squirrels that show up on her property. Furthermore, they did not agree to let
Sophie go either. Additionally, upon Sophies demise Mrs. Andover may replace her with another
pet dog.
I understand that this may be a cause of concern for you, however, Sophie or another dog
will be a domesticated indoor animal that will be completely under Mrs. Andovers care and
control. She is willing to assume full responsibility in this matter and hence, there will be a very
minute chance if any, of that animal being a threat, or any question in regards to its ownership.

Furthermore, in exchange for not allowing any outside animal in or around her house,
Mrs. Andover wants to spend some time with animals on a periodic basis in a controlled
environment. She wants you to accompany her to an animal shelter to help her with the healing
process of losing Winston, this whole incident, as well as getting back on normal terms with you.
We complied since we know that mending fences is in your common interest, and this will
ensure no more future threat to Billy or other children.
One of the final terms of her offer is, that any stray animal that shows up on her property
should not be send to the center for animal care and control, but to a shelter of your choosing, so
that there is no risk of it being euthanized.
Lastly, we informed Mrs. Andovers counsels of you wanting some type of apology from
her. Her counsels agreed to this condition provided you offer Mrs. Andover an apology as well.
She felt that your brining this lawsuit against her caused a negative impact on her overall image
in the community. She would have much rather preferred you approaching her directly instead of
taking a legal action.
I suggest we agree to this. This way there will be no strain left between you and her.
Knowing about your current financial situation as well as the strengths and weaknesses of
our case, I strongly recommend that the offer proposed by Mrs. Andover is in our favor and you
should consider accepting it. If you decide not to accept this offer and go through the litigation
process, there will be no financial assistance offered to you until this lawsuit is over.
Furthermore, there will be added costs related to the litigation process such as attorney and court
fees, as well as other miscellaneous expenses that you will have to bear from your own pocket.
Also, there always lies a risk of us losing the case in which situation you may end up getting no
monetary help at all. Lastly, there is a chance of Billy having to go through the trial process if
need arises.
Kindly call my office to set up an appointment where I can personally explain you the
terms of this offer in detail, as well as answer any other concerns that you may have. Also, if you
do decide to go through the litigation process, then we can discuss about that as well.
Sincerely,
Puruda Kothari, Esq.