Prepare a CLIENT questionnaire and use the fact pattern below. Your client is the

Prepare a CLIENT questionnaire and use the fact pattern below. Your client is the

prospective plaintiff that wants to sue. The Questionnaire should contain ALL THE

“BEYOND THE BASICS” INFORMATION in addition to the personal data, date/place of

incident, and how did the incident occur. The student is reminded that the text, and in

particular the lecture, identified several other key areas of which the paralegal should

include in their questionnaire and inquire from the prospective client.

2. Continuing with the same fact pattern as your questionnaire (Plaintiff Jessica Heweitt), draft

a Complaint with all appropriate allegations, and all applicable causes of action (there

clearly is more than one cause of action that should be pled), and in the correct format as

was taught in class, and detailed in the supplemental email I sent during the course. Also,

include all appropriate Defendants.


Jessica Hewitt is our client. She has been unemployed for over a

year and has been recently receiving counseling and medication

treatment for depression. Ms. Hewitt is claiming damages as a

result of an auto accident and an employment discrimination claim.

The driver that Ms. Hewitt collided with is Evan Portman, an

employee of Douglas Financial Services, Inc. Prior to the collision,

Evan Portman attended a Douglas Financial office party where he

consumed alcohol. Ms. Hewitt attended that same office party as an

invited guest of a different Douglas Financial employee. While

attending Ms. Hewitt met with the President of Douglas Financial in

hope of being hired by him. She was denied employment. Ms.

Hewitt believes that Douglas Financial should also be liable for the

accident because it provided alcohol to Evan Portman. Also, she

believes she was denied employment because of gender

discrimination. Ms. Hewitt wants to sue both defendants for all

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