Post Interview Memorandum in Shayla Smith swimming case
Stacy M. Portillo
PA299 – Post Interview Memorandum
August 18, 2013
TO: File
FROM: Polly Paralegal
DATE: August 18, 2013
RE: Client interviews with Mary Smith (mother) and Shayla Smith (minor child) on August 12, 2013
This is a case involving injuries sustained by Shayla Smith, a 10 year old girl, who was injured while swimming, unsupervised, with her friend Tamara. The girls were swimming in the pool at the O&D Campgrounds at 9:30 a.m. on April 30, 2010
Clients: Mary Smith (mother) & Shayla Smith (10 year old girl – injured party) Mary’s date of birth: 5/1/1968; Shayla’s date of birth: 2/16/2000
Date of incident: 4/30/2010
ISSUE:
This case involves the issue of Shayla Smith, a minor child, who was injured when she and her friend Tamara went swimming (unsupervised) at the O&D Family Campground swimming pool. Mary Smith, Shayla’s mother, believes Bob and Susan Tuttle, Tamara’s parents, are liable for not properly supervising Shayla, and by the Joneses and O&D Family Campground for negligence and both for breach of duty.
EVALUATION:
First, I met with Mary Smith, mother of Shayla Smith. Mary Smith explained that Tamara is Shayla’s best friend. The girls have known one another for years; the parents have met and know one another; and the girls play together and have sleepovers at one another’s houses regularly.
Mary is a single mother to Shayla. She works as secretary. She appears well-groomed and is fairly well-spoken. Shayla’s father is not involved in her life, and does not contribute to her support. Mary and Shayla have medical insurance through Mary’s employer, but Mary indicates it is not very good health insurance.
Mary was willing to answer any and all questions. She indicated she does have some medical records that she can provide to us, and she is willing to sign an authorization for us to obtain additional medical records, ambulance records, and hospital records.
Mary expressed several
PA299 – Post Interview Memorandum
August 18, 2013
TO: File
FROM: Polly Paralegal
DATE: August 18, 2013
RE: Client interviews with Mary Smith (mother) and Shayla Smith (minor child) on August 12, 2013
This is a case involving injuries sustained by Shayla Smith, a 10 year old girl, who was injured while swimming, unsupervised, with her friend Tamara. The girls were swimming in the pool at the O&D Campgrounds at 9:30 a.m. on April 30, 2010
Clients: Mary Smith (mother) & Shayla Smith (10 year old girl – injured party) Mary’s date of birth: 5/1/1968; Shayla’s date of birth: 2/16/2000
Date of incident: 4/30/2010
ISSUE:
This case involves the issue of Shayla Smith, a minor child, who was injured when she and her friend Tamara went swimming (unsupervised) at the O&D Family Campground swimming pool. Mary Smith, Shayla’s mother, believes Bob and Susan Tuttle, Tamara’s parents, are liable for not properly supervising Shayla, and by the Joneses and O&D Family Campground for negligence and both for breach of duty.
EVALUATION:
First, I met with Mary Smith, mother of Shayla Smith. Mary Smith explained that Tamara is Shayla’s best friend. The girls have known one another for years; the parents have met and know one another; and the girls play together and have sleepovers at one another’s houses regularly.
Mary is a single mother to Shayla. She works as secretary. She appears well-groomed and is fairly well-spoken. Shayla’s father is not involved in her life, and does not contribute to her support. Mary and Shayla have medical insurance through Mary’s employer, but Mary indicates it is not very good health insurance.
Mary was willing to answer any and all questions. She indicated she does have some medical records that she can provide to us, and she is willing to sign an authorization for us to obtain additional medical records, ambulance records, and hospital records.
Mary expressed several