File Opening Memo

TO: FILE

FROM: HHW

SUBJECT: SUSAN SMITH

DATE: OCTOBER 1, 1992

CLIENT: SUSAN SMITH

1046 FRANSVILLE AVENUE

PITTSBURGH, PA 19312

TELEPHONE: 555-4321 (H)

555-7777 (W)

REVCO REALTY

4000 OHIO BLVD.,

PITTSBURGH, PA 19311

SALES AGENT

SS# 199-25-4009

DOB 7/18/59

DATE OF ACCIDENT: JUNE 10, 1991

STATUTE OF LIMITATIONS: JUNE 9, 1993

DEFENDANT: JUDITH ANDERSON

1515 STOCKTON BOULEVARD

MARSVILLE, PA 19110

NOTE: Both the plaintiff and defendant are insured by the Liability Insurance Company.

Susan Smith makes a wonderful impression. She is a young widow (John Smith, who had been a manager at Service Merchandise) and has two boys ages 12 and 13, even though she is only 32 years of age.

The case was referred to us by John Brandon, Esq.

Susan was stopped on Rt. 65 in Connor, PA, Beaver County, because traffic in front of her had stopped for a dog. Judith Anderson, behind Susan, did not notice that traffic was stopped and hit her from behind at approximately 45 mph.

Susan was treated at Saint James Hospital Emergency Room and since then has seen a number of doctors. They are listed on her Client Information Sheet. The case is referred to Karen Albright with instructions to please write all the doctors and Saint James Hospital and Medical Rehabilitation Institute, and her current...