He will be considered a trespasser DECEMBER 7 McManus
I received this today.
Philip E. Johns
Johns & Johns, LLC
6782 Broad Street
Douglasville, GA30134
770-949-3400
Fax: 770-949-2561
Cell: 678-480-1592
Email: johnslaw@comcast.net
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From: John McManus [mailto:JMcManus@mcmanus-law.com]
Sent: Wednesday, December 07, 2016 11:08 AM
To: Philip E Johns
Cc: Jarrod Plunkett
Subject: RE: Claudio Avendano
Phillip:
As discussed last week, my client allowed your client, Claudio Avendano, access to the building he purchased from your client’s bankruptcy estate located at 155 Liberty Road, Villa Rica, GA both Monday and yesterday from 7AM until 7PM. Your client took small amounts of property Monday, and Tuesday at 4:30PM finally brought out a large U-Haul truck to get the rest….at 7PM, as agreed by the parties, our client advised Mr. Avendano to cease work and exit the property. Your client apparently wanted more time but our client was firm on 7PM, as discussed. All remaining personal property will be disposed of during the clean-up phase of the current renovation.
Therefore, as agreed, your client is not to come on the property at 155 Liberty Road, Villa Rica, GA for any reason, and if he does come on the property he will be considered a trespasser and the police will be called. As discussed, our client does not intend to deal with your client any further. Our client is now undertaking to renovate the subject building and use it for his business purposes, and no further interference by Mr. Avendano will be tolerated.
We appreciate your efforts in this matter and hope this matter, as it relates to your client, is finally concluded. Please advise any questions or concerns. John
John J. McManus & Associates, P.C.
4500 Hugh Howell Road, Suite 510
Tucker, GA 30084
770-492-1000
770-492-1100 [fax]
800-849-8498 [toll free]
jmcmanus@mcmanus-law.com
From: John McManus
Sent: Friday, December 02, 2016 11:16 AM
To: 'Philip E Johns' <johnslaw@comcast.net>
Cc: 'Jarrod Plunkett' <jarrod_plunkett@msn.com>
Subject: RE: Claudio Avendano
I have…it sucks….it’s easier to deal with surgery etc for the animals….I’ve attached a corrected copy…I had a typo…hope your wife is doing better…also your dog…John
John J. McManus & Associates, P.C.
4500 Hugh Howell Road, Suite 510
Tucker, GA 30084
770-492-1000
770-492-1100 [fax]
800-849-8498 [toll free]
jmcmanus@mcmanus-law.com
From: Philip E Johns [mailto:johnslaw@comcast.net]
Sent: Friday, December 02, 2016 10:59 AM
To: John McManus <JMcManus@mcmanus-law.com>
Subject: RE: Claudio Avendano
John,
I am sorry for not getting the form to you. I had to get my wife out of the hospital and settled in and new meds from the pharmacy and flooded office buildings.. I hope you never have to deal with our health care system.
Philip E. Johns
Johns & Johns, LLC
6782 Broad Street
Douglasville, GA30134
770-949-3400
Fax: 770-949-2561
Cell: 678-480-1592
Email: johnslaw@comcast.net
Confidentiality Notice
This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.
From: John McManus [mailto:JMcManus@mcmanus-law.com]
Sent: Friday, December 02, 2016 10:56 AM
To: johnslaw@comcast.net
Cc: Jarrod Plunkett
Subject: Claudio Avendano
Phillip: I have not received the Liability Waiver agreement we discussed yesterday so I prepared one and have attached it for your review….the original of this executed agreement must be provided to Mr. Plunkett Monday before your client, or anyone else, will be allowed on the Property. Mr. Plunkett will have similar agreements for anyone else claiming property from the building as well….please advise any questions…thanks…John
John J. McManus & Associates, P.C.
4500 Hugh Howell Road, Suite 510
Tucker, GA 30084
770-492-1000
770-492-1100 [fax]
800-849-8498 [toll free]
jmcmanus@mcmanus-law.com