Raj V.

Abhyanker
+ 408 398 3126
raj@legalforcelaw.com

October 22, 2018

Gilda R. Turitz
Turitz Dispute Resolution
Four Embarcadero, Suite 1400
San Francisco, CA 94111

Re: LegalForce RAPC Worldwide, P.C. vs. LegalZoom.com, Inc.,

Case No. 01-18-0001-5162

Dear Arbitrator Turitz:

This letter will serve as Claimant LegalForce RAPC Worldwide P.C. ("LegalForce" or
the
“Claimant") response to LegalZoom.com, Inc.'s ("LegalZoom" or the "Respondent")
request to file a dispositive motion for judgment on the pleadings for five of the nine
claims as a matter of law.

A. PRELIMINARY STATEMENT AND BACKGROUND.

LegalZoom was founded in 1999 on a web of lies. When suspended attorney

Brian Lee founded LegalZoom in 1999, he was more interested in making a profit than
helping small businesses. He embarked on LegalZoom’s trajectory of deception by first
inventing a false narrative, that it was not he, a suspended attorney, but rather a famous
criminal defense lawyer Robert Shapiro that created LegalZoom. In reality, Brian Lee
met Robert Shapiro through a cold call solicitation.

For years, LegalZoom has evaded government scrutiny and regulators through
bullying and a systematic web of lies. Whenever it has been sued by private parties, it
has tried to force plaintiffs into arbitration as it has done here. Whenever threatened by
regulators, LegalZoom has ramped up lobbying efforts and even sued State Bar ethics
committee participants in their personal name.
 All the while, LegalZoom has tried to carve for itself a monopoly, harming
competition from law firms and entrepreneurial lawyers who follow the law and rules
including the Plaintiffs.

As technology advances and opens up new opportunities for efficiency and

cost-savings, legal professionals must work within the existing professional framework
until necessary precautions and changes are made to facilitate change that protects
members of the legal profession and clients that rely on the legal services​. In America
where few average citizens can afford hourly rates of lawyers, it is a noble and
worthwhile cause to improve access to justice and access to law through the web and
through the Internet. ​That is what the Claimant has precisely done.

However, opening up access to law and justice should not mean abandoning
fundamental principles of ethics and integrity that are the bedrock of the American legal
system. While RAPC has served this higher purpose within the current regulatory
framework, some are willing to restrain trade, using outsized external capital to ignore
current ethical rules and turning a blind eye to common sense in pursuit of monopoly.

B. COUNT II FOR CONSPIRACY TO RESTRAIN TRADE, SHERMAN ACT, 15

U.S.C. § 1 IS NOT RIPE FOR DISPOSITIVE MOTION.

Claimant disagrees with Respondents that a dispositive motion is ripe with respect
to this claim. In order to save arbitration costs and to streamline this arbitration in view
of the accelerated schedule for this arbitration and the limits of five (5) depositions per
side, Claimant withdraws this claim from this arbitration but expressly reserves the right
to pursue it in a separate litigation or arbitration.

C. COUNT III FOR MONOPOLY TO RESTRAIN TRADE, SHERMAN ACT, 15

U.S.C. § 2 IS NOT RIPE FOR DISPOSITIVE MOTION.

Claimant disagrees with Respondents that a dispositive motion is ripe with respect
to this claim. In order to save arbitration costs and to streamline this arbitration in view
of the accelerated schedule for this arbitration and the limits of five (5) depositions per
side, Claimant withdraws this claim from this arbitration but expressly reserves the right
to pursue it in a separate litigation or arbitration.

D. COUNT IV CALIFORNIA FALSE & MISLEADING ADVERTISING ("FAL").

Claimant disagrees with Respondents that a dispositive motion is ripe with respect
to this claim. In order to save arbitration costs and to streamline this arbitration in view
of the accelerated schedule for this arbitration and the limits of five (5) depositions per
side, Claimant withdraws this claim from this arbitration but expressly reserves the right
to pursue it in a separate litigation or arbitration.

E. COUNT VI CONSUMER LEGAL REMEDIES ACT ("CLRA").

Claimant disagrees with Respondents that a dispositive motion is ripe with respect
to this claim. In order to save arbitration costs and to streamline this arbitration in view
of the accelerated schedule for this arbitration and the limits of five (5) depositions per
side, Claimant withdraws this claim from this arbitration but expressly reserves the right
to pursue it in a separate litigation or arbitration.

F. COUNT VIII: UNJUST ENRICHMENT.

Claimant disagrees with Respondents that a dispositive motion is ripe with respect
to this claim. In order to save arbitration costs and to streamline this arbitration in view
of the accelerated schedule for this arbitration and the limits of five (5) depositions per
side, Claimant withdraws this claim from this arbitration but expressly reserves the right
to pursue it in a separate litigation or arbitration.

For the reasons stated above, Claimant respectfully requests that the Arbitrator
deny LegalZoom’s request to file a dispositive motion as moot.

Respectfully,

Raj Abhyanker
Counsel for Claimant