EPR Task 1 Activity 2 File Note template

File Note
Date: 23rd January 2019 Start time: 12:00 pm Units:
End time: 12:15 pm
Matter: Prevention of Disciplinary Action Matter
number:
Type of
attendance:
Telephone: Where:

Other:

By whom: MEGAN SAUNDERS On whom: MARTIN MOODY

Details
Megan Saunders and Martin Moody have reached an understanding with regards to the pending issue of
potential defamatory Facebook posts being posted by Susan Peters against Isabella Grunsky which is
adversely impacting the business of the former. In order to ensure that the posts are taken down, the
complete settlement amount of $ 25,000 was paid in a period of two days. However, the Facebook posts
were not taken down even after two weeks had passed from the payment date owing to which displinery
action was threatened.

Next steps: 1) Payment of $ 3,500 each would be made to Susan By whom: 1) Megan Saunders
Peters & Martin Moody
2) Facebook posts containing defamatory content against
Isabella Grunsky would be taken down within 24 hours 2) Susan Peters &
of the receipt of $ 7,000 payment by Susan Peters. Martin Moody

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Megan Saunders: I am sorry for the tone of my email the other day. I thought we had an understanding and
had to persuade my client to make the requisite payment which was made after much hardship. The posts
on Facebook are causing considerable damage to my client’s business interests and since the outstanding
amount has been paid, I suggest that you get these taken down.

Martin Moody: I agree that the requisite payment has been made. I am willing to take down the Facebook
posts which I had posted. But my client is unwilling to take down her Facebook posts as there is a $ 7,000
shortfall owing to the legal costs borne. She is willing to take down those posts if your client agrees to settle
$7,000 more.

Megan Saunders: Martin, you have got to understand that at the first place my client did not make the
payment owing to financial stress. I have not received even a dime in my legal fees and it seems that is quite
far at this time. There is no way my client would entertain such a proposal. Also, we had an agreement
whereby you gave your personal undertaking with regards to taking down the posts. This new request is
clearly ridiculous.

Martin Moody: I am sorry but I cannot help you in this regards. And I hope you know I still have the choice of
taking the mail you sent me yesterday directly to the legal board.

Megan Saunders: See my client cannot make anymore payment. If it is possible can we split this payment?

Martin Moody: No, you have to pay the entire amount. Why should I bear the burden of your client?

Megan Saunders: Come on Martin! You know we both are caught up in this situation where we are both
risking our career for what. Let us get this done with.

Martin Moody: Ok I agree to your proposal. Once the payment of $ 7,000 is made to Susan Peters, Facebook
posts would be taken down within 24 hours.

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