Internal Legal Memorandum

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Internal Legal Memorandum
PA299: Associates Capstone in Paralegal Studies
Kynyatta Weaver
Professor: Monica Ross
Kaplan University
Saturday, August 06, 2011

Legal Memorandum
TO: Attorney Monica Ross
FROM: Paralegal Kynyatta Weaver
DATE: August 6, 2011
SUBJECT: Personal Injury
On April 30, 2008 around 9:30 a.m. an incident involving Shayla Smith occurred at the O&D Family Campground. The question is to whether the campground was negligent when securing the pool area where the incident occurred. Our client is Mary Smith the mother of Shayla Smith. Shayla Smith went to the O& D Family Campground owned by Owen and Dolly Jones, with her friend Tamara and her parents Bob and Susan Tuttle. On the day of the incident the girls snuck out of the family living area and went to the pool area in the campground. When the girls go to the pool there was a lock on the pool but the lock had been broken, it was just there as a deterrence. The girls opened the gate and proceeded to enter the pool, Tamara went in first yelling that the pool was shallow, but Shayla did not hear her and proceeded to follow her in, and when she dove in and she broke her arm. Tamara saved Shayla by pulling her to the side of the pool and yelling for help. Shayla was taken by ambulance to the hospital and was treated putting a cast on followed by physical therapy. The Tuttles’ called Mary Smith on the way to the hospital as they followed the ambulance. This is Shayla’s first injury. Shayla has been diagnosed with ‘dyslexia’ (a learning disorder involving reading). ISSUES

1. Were the owners of O&D Family Campground, Owen and Dolly Jones guilty of negligence by not proving a new lock for the pool gate? 2. Were owners Owen and Dolly Jones negligent by only having signs on display when the pool area was open instead of having them on display at all times? SHORT ANSWER

1. Yes, the owners of the O&D Family...
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