Personal Injury Case Involving Automobile Accident

A new case in the office has been added to your work assignments.  Your employer: Barnes & Brown, LLP is a law firm specializing in plaintiff personal injury work.  For this assignment you will primarily work with attorney Stephen Barnes, SBN 123456. There are five attorneys in the office, two paralegals, three legal secretaries, a file clerk, and a full-time receptionist. The office is located at:24012 Calle De La Plata, Suite 400, Laguna Hills, CA 92653, (714) 459-5500, fax (714) 459-0055. The case involves personal injuries resulting from an automobile accident.

The accident occurred on February 7, 2020, at 8:30 p.m. It was dark. Officer Mary McFarland, ID# 69712, of the Costa Mesa Police Department prepared and signed the accident report. The report indicates that all controls at the intersection were functioning. Our client had entered the intersection traveling approximately 10 to 15 mph. According to the report, the defendant was exceeding the speed limit and approaching the intersection, clearly in a hurry.

Witness No. 3 was walking East on Adams Street across from the Mesa Verde shopping center and Acapulco restaurant. She was in front of the fire station when she looked over when she heard the crash. Witness No. 1 was headed to eat at Soup Plantation after leaving his appointment at the OC Eye Designs in the Mesa Verde shopping center. Witness No. 2 had stopped on the South side of the Adams and Royal Palm intersection behind a delivery truck in the right-hand lane but still had good visibility of the next lane over. All three witness statements appear to support our clients’ recollection, but Witnesses No. 1 and No. 2 make statements that clearly support our clients’ position.

Our Client Garrison Stephens was traveling South on Royal Palm, entered the intersection turning left onto Adams and was struck by the defendant, Injuries included numerous cuts, a broken left leg and left collarbone, severe pain in the neck and back, and multiple bruises.  All injured persons were transported to Hoag Hospital. Amanda Stephens, born 9/15/2006, was a passenger in the car and was badly injured, shaken, bruised, and cut, with extensive internal injuries and was also transported to Hoag Hospital. Mother Shelley Stephens was notified immediately.

The Defendant Jeff Richardson was traveling West on Adams Street, failed to stop for the red light and the collision occurred at an estimated speed of 45 mph. The defendant complained of back, neck and head injuries and his vehicle was also towed and he was taken to Hoag Hospital. A citation was issued for exceeding the speed limit and failure to stop at a red light. Richardson has not given a statement to police yet.

Neither party was tested for alcohol or drugs at the scene. Both vehicles were towed from the scene to Costa Mesa Tow Truck Company 1590 Adams Ave. #4311 Costa Mesa, CA 92628. 

Witness No. 2 remembers that there were several people in the parking lot of the Acapulco but did not get any names. The officer might have notes and there were also people standing around on the Adams and Royal Palm corner, but no names are mentioned in the police report.  

The Defendant is the President of Castaway Inc., a California corporation. Richardson was on his way to a corporate presentation for the company at the Westin Hotel in Costa Mesa. He had spent the day with friends golfing at the Mesa Verde Golf Course. He was not looking forward to going to the presentation but felt there was sufficient time to get there in time. The Tesla is a company leased vehicle with full autopilot capabilities according to the Tesla website tesla.com/support/autopilot. The Castaway corporate headquarters are located at: 725 Figueroa, Suite 250, Los Angeles, CA 90002, (213) 417-1855.

Using the Discovery Plan you created in Module 13, please prepare 5 Special Interrogatories, a set of Form Interrogatories, 5 Requests for Production, 5 Requests for Admission. Please use pleading style similar to the examples provided.