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Graded Project 2 Torts

In: Other Topics

Submitted By juliomadarriaga
Words 1231
Pages 5
TO: Steve Stinson Esquire

FROM: Paralegal

DATE: March 18, 2015

RE: Smith v. Growler's Groceries

This memorandum summarizes my interview and findings with Ms. Jones and summarizes Ms. Jones' credibility as a witness. The memorandum also includes the duty of care owed by the Growler's groceries store to it's customers. Additionally, included are facts that show that Growler's grocery store did not comply with the applicable standard of care.

INTERVIEW OF ROBIN JONES

I spoke with Ms. Jones at her home on Friday, March 1, 2015 at 9:30 AM. She is a Caucasian woman of petite height and build. She was clothed in her jogging outfit having just returned from her morning run. Ms. Jones demeanor was grim and long-faced as if she dreaded having me interviewing her, but she did offer me a seat and beverage.

Ms. Jones admitted witnessing the slip and fall of Sally Smith. Ms. Jones recalled that she saw the blue liquid one the floor. She remembers the spill to be about 2 feet wide and 2 feet long and the source of the puddle was from a liquid floor detergent that according to her, “must have fallen from the shelf” onto the aisle floor. Ms. Jones stated that when she saw the spilled liquid she notified her supervisor,, assistant manger, Percy Potter. Ms. Jones stated she was instructed by the assistant manager to place multiple, caution spill clean up in progress signs, around the spill while the assistant manger called for someone from the maintenance crew to clean up the spill. As she returned to the aisle to place the signs around the spill Ms. Jones witnessed Sally Smith coming down the aisle with her shopping cart containing her two-year old child. Ms. Jones states Ms. Smith was looking down at items in her shopping cart when she came across the puddle. Ms. Jones states that she “hollered” at Ms. Smith “careful there's a spill there”, but Ms. Smith…...

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