Unit 1: Assignment
Unit 1: Internal Memorandum
judgenjurysherry
Kaplan University
TO:
From: Sherry Metz, Paralegal
Date: 31 March 2015
Re: Shirley Uber Caretaker
Ms. Shirley Uber Caretaker is a 56 year old woman seeking counsel regarding a potential disability Claim. Mrs. Caretaker is a widow, who has worked since she was 16 years old. Mrs. Caretaker has been employed as a janitor, bagger, cashier, CNA and worked her way through school to become an LPN. The following facts are relevant to her claim.
Facts:
1) Mrs. Caretaker has been working as a LPN for 10 years. A year ago, while at work, Mrs. Caretaker dropped a bottle of pills on the floor. When she bent down to pick of the pills, she slipped on a pill and fell to the ground. On her way down she grabbed a filing cabinet in an attempt to stop her fall. The heavy cabinet fell over and landed on her back.
2) Mrs. Caretaker has severe knee pain. Mrs. Caretaker’s knee pain could be the result of working over 25 years caring for patients. Mrs. Caretaker worked in a nursing home as a CNA and then in the local hospital as an LPN. The physical demands as a CNA and LPN likely attributed to knee pain. Both jobs demanded lifting patients and standing on her feet 80% of the time.
3) Mrs. Caretaker did not receive workmen’s compensation or unemployment insurance benefits. Mrs. Caretaker however did receive short term disability for 6 months. Mrs. Caretaker was terminated after the 6 months disability, as she was unable to return to work. She has been awarded Long Term Disability from the employer’s insurance provider.
4) Mrs. Caretaker is on COBRA insurance, which is about to expire. COBRA does not pay for all of the medical expenses Mrs. Caretaker requires. Mrs. Caretaker requires medication, surgery and medical supplies, which COBRA does not cover.
5) Mrs. Caretaker is paid $350 dollars per week, by her son, to care for his two children ages 15 and 17. Mrs. Caretaker supervises the children 2
judgenjurysherry
Kaplan University
TO:
From: Sherry Metz, Paralegal
Date: 31 March 2015
Re: Shirley Uber Caretaker
Ms. Shirley Uber Caretaker is a 56 year old woman seeking counsel regarding a potential disability Claim. Mrs. Caretaker is a widow, who has worked since she was 16 years old. Mrs. Caretaker has been employed as a janitor, bagger, cashier, CNA and worked her way through school to become an LPN. The following facts are relevant to her claim.
Facts:
1) Mrs. Caretaker has been working as a LPN for 10 years. A year ago, while at work, Mrs. Caretaker dropped a bottle of pills on the floor. When she bent down to pick of the pills, she slipped on a pill and fell to the ground. On her way down she grabbed a filing cabinet in an attempt to stop her fall. The heavy cabinet fell over and landed on her back.
2) Mrs. Caretaker has severe knee pain. Mrs. Caretaker’s knee pain could be the result of working over 25 years caring for patients. Mrs. Caretaker worked in a nursing home as a CNA and then in the local hospital as an LPN. The physical demands as a CNA and LPN likely attributed to knee pain. Both jobs demanded lifting patients and standing on her feet 80% of the time.
3) Mrs. Caretaker did not receive workmen’s compensation or unemployment insurance benefits. Mrs. Caretaker however did receive short term disability for 6 months. Mrs. Caretaker was terminated after the 6 months disability, as she was unable to return to work. She has been awarded Long Term Disability from the employer’s insurance provider.
4) Mrs. Caretaker is on COBRA insurance, which is about to expire. COBRA does not pay for all of the medical expenses Mrs. Caretaker requires. Mrs. Caretaker requires medication, surgery and medical supplies, which COBRA does not cover.
5) Mrs. Caretaker is paid $350 dollars per week, by her son, to care for his two children ages 15 and 17. Mrs. Caretaker supervises the children 2