Stephen J. Bolin

Writing Samples

Writing Sample 1

Complaint for Negligence

This writing sample is a Complaint for Negligence filed in the Second Judicial District Court of Washoe County, Nevada, on behalf of Plaintiff John Michael Anderson against Defendant Christopher Alan Smith, a grocery store owner. The document includes:

  • Parties, Jurisdiction, and Venue: Establishes that the case arises from events occurring in Washoe County, Nevada, and that the Court has jurisdiction under Nevada statutes.
  • General Allegations: The Plaintiff was injured on the Defendant’s premises when a defective freezer door, known to be hazardous, swung back forcefully and struck the Plaintiff. The Defendant had prior knowledge of the defect and failed to address the issue or warn customers.
  • Cause of Action – Negligence:
    • Duty: Defendant owed a duty of care to maintain the premises in a reasonably safe condition for invitees.
    • Breach: Defendant failed to repair, replace, or provide warnings regarding the defective freezer door.
    • Causation: Defendant’s breach directly caused the Plaintiff’s injuries.
    • Damages: The Plaintiff sustained physical injuries, emotional distress, medical expenses, and lost wages, among other damages.
  • Prayer for Relief: Seeks compensatory damages, costs of the suit, attorney fees (if applicable), and other appropriate relief, with damages exceeding $15,000.

This sample demonstrates the ability to draft a detailed and well-structured legal complaint, effectively outlining the elements of negligence and articulating the Plaintiff’s claims.

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WRITING SAMPLE 2

COMPLAINT UNDER THE FREEDOM OF INFORMATION ACT

This writing sample is a Complaint Under the Freedom of Information Act (FOIA) filed pro se by Stephen J. Bolin in the United States District Court for the District of Nevada. The document includes:

  • Introduction: The complaint seeks to compel the Office of the Director of National Intelligence (ODNI) to process a Mandatory Declassification Review (MDR) request submitted by the Plaintiff. The FOIA provides the statutory right for judicial review when an agency refuses to comply with its disclosure obligations.
  • Jurisdiction and Venue: The case is properly filed in Nevada under applicable statutes, as the Plaintiff resides in the district.
  • Factual Allegations: The Plaintiff alleges that the ODNI unlawfully refused to process an MDR request for records concerning “Immaculate Constellation,” despite the request being sufficiently specific under FOIA standards. An appeal of this decision was improperly deemed non-appealable by ODNI.
  • Cause of Action: The complaint asserts that ODNI violated FOIA by refusing to process the MDR request, failing to conduct a reasonable search for records, and neglecting to disclose segregable portions of non-exempt information.
  • Relief Requested: The Plaintiff requests a court declaration that ODNI’s actions violate FOIA, an order compelling ODNI to process the MDR request, and an injunction preventing similar refusals in the future.

This sample highlights the Plaintiff’s ability to analyze and apply federal statutes, present factual and legal arguments, and seek appropriate judicial remedies.

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WRITING SAMPLE 3

DEFENDANT’S REQUEST FOR DISCOVERY

This writing sample is a Defendant’s Request for Discovery prepared in the case of Smith & Weer, P.C. v. Stephen Bolin (Case No. 2024-LM-205) filed in the Tenth Judicial Circuit Court of Tazewell County, Illinois. The document includes:

  • Interrogatories: Detailed questions directed to the Plaintiff, Smith & Weer, P.C., seeking information about electronic file handling, deletion practices, employee actions, and allegations against the Defendant. It also inquires about specific incidents, emails, and alleged damages.
  • Requests for Production of Documents: Demands for documents, including metadata, email communications, access logs, and evidence related to the Plaintiff’s claims, as well as documentation of internal policies and prior disciplinary actions.
  • Certification and Service: Statements affirming the good faith intent of the discovery requests and confirmation of service to the Plaintiff’s representatives.

This sample showcases the Defendant’s legal strategy in utilizing discovery tools to address allegations of file deletion and improper system access while also highlighting procedural and substantive diligence.

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