Post Interview Memorandum

See the sample post-interview memorandum below, as well as the description that follows it. Also see the Sample Interview Summary based on your initial interview of Mary Smith, Shayla's mom. The seminar "interview" will be your initial meeting with Shayla and your follow-up interview of Mary.

Client Evaluation

(Preamble):

Evaluation of Mary Smith

Date: 6-1-2008

[Put Issue here]

Client Impression: Mary Smith is the mother of the injured child, Shayla. She is Caucasian, weighs approximately 150 lbs., and is 5'2". She has a full head of dark brown hair worn at shoulder length. Mary is a secretary in a small insurance agency and is dressed professionally in a black suit.

Mary was cooperative during the interview and was very responsive to my questions. However, she did not bring in any documentation though we had requested her medical bills, etc.

Mary repeatedly asked me how long the case would take and mentioned her "large bills" from Shayla's accident several times. Mary is a single mother, and Shayla's father is not really in the picture and provides no financial support for Shayla's care. Mary does not have any kind of insurance.

I found Mary to be a nice-looking woman though a bit frazzled. 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.

[Put Facts Here]

Fact Questions:

Where is the campground located?

Who was supervising Shayla and Tamara?

What is the layout of the pool? How deep and large is it?

Were there any signs around the pool?

Is there a lifeguard on duty?

Have there been previous incidences at this campground pool?

I am not sure Mary and Shayla have a viable case, as more investigation is needed. Recommend that we do the following fact development:

More contact with client regarding bills and treatment

Interviews with all witnesses, including ambulance personnel

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