Post Interview Memorandum - Shayla Smith

POST INTERVIEW MEMORANDUM

TO: ATTORNEY SMITH

FROM: XXXXXXXXXX

SUBJECT: EVALUATION OF MARY SMITH (MOTHER) & SHAYLA SMITH (A MINOR VICTIM)

DATE: SEPTEMBER 16, 2014

CC: FILE

This particular case involves injuries sustained by 10 year old Shayla Smith, who was injured while swimming without supervision with her friend Tamara. This occurred in the pool at the O&D Campgrounds at approximately 9:30 a.m. on April 30, 2014.

ISSUE

Mary Smith would like to bring suit against The Tuttle’s, Tamara’s parents, for not properly supervising Shayla, as well as the owners of O&D Family Campground for negligence.

EVALUATION

First, I met with Mary Smith, mother of Shayla Smith. Mary Smith explained that Tamara is Shayla’s best friend. In fact, the girls play together and have sleepovers at one another’s houses on a regular basis. The two families have known each other for years.

Mary Smith is a single mother to Shayla. She works as secretary. She appears well-groomed in a black suit and is fairly well-spoken. Shayla’s father is not involved in her life, and does not contribute to her support. Mary does not have health insurance through her employer. Shayla is ten years of age, weighs approximately 150 lbs. and is 5’2” tall.

Mary was cooperative during the interview and was very responsive to my questions even though she did not bring in any documentation though we had requested her medical bills, etc. However, Mary Smith is willing to sign an authorization for us to obtain any medical records associated with this incident. Mary was very interested to know me how long the case would take and mentioned the "large bills" from Shayla's accident several times.

In the end, I found Mary to be a nice-looking woman though a bit frazzled and unprepared. She was articulate but talked a little loudly. I think she would make a good impression on a judge or jury, but she is a little anxious to "score the big one" for Shayla's injuries.

FACTS

1. Shayla Smith went on...