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Tombers and Associates PC 300 South Capitol Avenue Lansing Michigan 48933 5

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Tombers and Associates PC 300 South Capitol Avenue Lansing Michigan 48933 5 Powered By Docstoc
					                              Tombers and Associates, PC
                              300 South Capitol Avenue
                              Lansing, Michigan 48933
                              517.371.5140
                              tomberse@cooley.edu

___________________________________________________________
____

                                 CLIENT INTAKE SHEET1

Case:           Timothy Cowling v. International Department Store and Sam
                     Security

Filing Deadlines: April 1, 2005 (negligence)
                  April 1, 2004 (false imprisonment)
                  April 1, 2005 (intentional infliction of emotional distress)

Interview Date: March 17, 2003

Client Name:           Timothy Cowling (through Sandra Cowling, next friend)
Address:               4424 High St., Lansing, MI 48917
Phone:                 (517) 371-5555

SS#               123-45-6789
Driver License #: None
Insurance:        None
Education:        3rd Grade

Employment History
    Current:                         None
    At time of incident:             None
    Prior Employment:                None
    Reason for leaving:              N/A (not applicable)

Parents Names: Sandra Cowling          DOB: 5/13/70
               Need to get father’s name




1
    Originally prepared by student Marilyn Tombs in Michaelmas Term 1998.


                                               1
                              CASE BACKGROUND

Opposing Party: International Department Store and Sam Security
Counsel:          Andrew Quinn (P33333), 217 S. Capitol Ave.,
                  Lansing, MI 48933 (517) 555-1212
Type of Incident: Negligence
Location:         Big Mall, 2000 W. Saginaw Hwy., Lansing, MI 48917
Time:             Approximately 11:30 a.m.
Date:             April 6, 2002

Reason for seeking Counsel: Initiate lawsuit
Referred by:                N/A

Witnesses:        Sarah Sawitall
                  200 Elm St.
                  Lansing, MI 48933

                  Clarence Confused
                  341 Poorvision St.
                  Lansing, MI 48911

                               CLIENT HEALTH

Past Injuries or Illnesses:    Broken right arm (radius bone) at age 5
Current Injuries:              Broken right arm (ulna), fractured lumbar
                               vertebra, deep facial lacerations and scarring
Current Physician:             Pediatrician (name currently unknown)
Treating Physicians:           Will Treatum, M.D. (orthopedic surgeon)
                               I.M. Nutt, Ph.D. (psychologist)

                                  DAMAGES

Ms. Cowling does not have health insurance for her family. To date, she has
been billed $20,000.00 for Timothy’s treatment. Timothy will need more
surgery and continuing counseling. Timothy is still in pain and suffers from
nightmares.

                              SUMMARY OF FACTS

On April 6, 2002, Timothy Cowling and his mother, Sandra Cowling, were at
the International Department Store at the Big Mall on the west side of town.
Ms. Cowling allowed Timothy to stay in the home electronics department while
she went to the linens department to make a quick purchase. A gang of older
boys, the Young Hoods, entered the home electronics department and began
creating a disturbance. Timothy was quietly playing a video game.



                                       2
      Sam Security, a big, burly security guard, thought the youths had stolen
something and rounded them all up, including Timothy. He took them to the
security office and interrogated them for about 25 minutes. He ejected all of
the boys from the store, including Timothy, and told them not to come back in.

      The Young Hoods again began roughhousing. One of them knocked
Timothy off of the sidewalk and into the path of an oncoming car. Timothy was
struck by the car, whose driver immediately fled. Neither the car nor the driver
have been found.




                                       3

				
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Description: sample form to use on or about first meetings with client.