To: Timothy L. Carlin, Attorney
From: Brenda Beauregard, Paralegal
Date: November 26, 2010
RE: Post Interview Memorandum
Client: Mary Smith on behalf of Shayla Smith minor child Subject Matter: Personal Injury
Date of incident: April 30, 2008
This confidential memorandum, which contains my thoughts, impression, and observations of June 1, 2008 interview with Mary Smith. In addition to my observation and information received, this memorandum includes my preliminary analysis and conclusions regarding the clients claim.
Mary Smith is the mother of the injured child, Shayla a minor. She is a Caucasian, approximately 5’2” about 150lbs. She has dark brown hair worn at shoulder length. Mary is a secretary in a small insurance agency and is dressed professionally wearing a black suit. She was cooperative during the interview and was very responsive to my questions. However, she was requested to bring to the interview any documentation, medical bills, etc. which she did not bring to the interview.
Mary repeatedly questioned how long the case would take and mentioned her “large bills” that have occurred from Shayla’s accident several times during the interview. Mary stated she was a single mom and Shayla’s dad provides no financial support for the care of Shayla and is not really in the picture. Mary also does not have any kind of insurance.
I found Mary to be a nice-looking woman; she was articulate, spoke a little loud, and a bit frazzled. She would make a good impression on the judge or jury, however she can be a little anxious to “score the big one” for Shayla’s injuries.
During the initial interview, Mary gave a synopsis of the incident bringing her to the office to seek legal advice. The following facts occurred on April 30, 2008 approximately 9:30am; the incident took place at the O&D Family Campground owned by...