Sherri Withrow Unit 7 Part 1

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Unit 9 Assignment - Research Assignment 4: Final Draft

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To: Janet Jones

Fr: XXXXXXXX, Paralegal

Date: XXXX, XX, 2011

Re: Sherman v. Tom Mardsen and the Church of the Divine Light, et. al., File No. 2120

This is my final draft of the research Memorandum responsive to all your final questions and comments requesting some appellate authority concerning false imprisonment. As you know this Memorandum is in response to your request, (following your meeting with Robert & Bunny Sherman April 2, 2011), that I conduct some preliminary research regarding possible causes of action that might be asserted against Tom Mardsen and/or the Church of the Divine Light by both Robert Jr., and his parents. You also requested me to outline the elements that must be proved for each cause of action as well as to the potential for damages that may be available to Robert, Bunny and Robert Sherman, Jr. I have updated the damages section to provide some appellate authority in response to your June 12, 2011 request.

This Memorandum addresses each of your requests regarding this case in sections titled:

i. Factual Allegations;

ii. Individual Plaintiff’s Causes of Action/Elements;

iii. Potential Damages Available to Plaintiffs;

iv. Appellate Authority

v. Conclusion.

I hope that this Memorandum fully addresses each of your concerns regarding this case. If you require any additional information or research in regards to this case please contact me at your earliest convenience.

Factual Allegations

The facts indicate that Robert Sherman and his wife, Bunny Sherman are the parents of Rob Sherman Jr., a 15 year old male. According to the interview notes, Rob Jr. was “tricked” into attending some meetings at the church of the Divine Light located here in San Diego. Approximately one...