LITIGATION CHART Negligence Elements of the Claim Sources of Proof Informal Fact Investigation Formal Discovery Problematic Areas Duty to take reasonable precautions to prevent foreseeable harm from dangers that the premises owner knew about, should have known about, or created. Official representative of International Department Store. Sam Security Sandy Security Clarence Confused Timothy Cowling Sandra Cowling None None None None Interview Interview Depositions, Interrogatories, Requests to Produce Documents to determine what Sam Security knew about Timothy and the Young Hoods. Also need to determine if Sam created the danger by expelling Timothy from the store. Duty owed to protect another from third party’s criminal acts? Was Timothy a foreseeable plaintiff? Was harm to Timothy from Young Hoods foreseeable? Breach of duty Sam Security Sandy Security Sarah Sawitall Timothy Cowling Sandra Cowling Clarence Confused None None Interview Interview Interview None Deposition Deposition Deposition Need to know if Sam escorted the youths outside the store. What did Sam say out there? Did Timothy try to say anything? What happened just before Sam took the youths to office? Causation Timothy Cowling Sandra Cowling Sarah Sawitall Clarence Confused Police Officers Interview Interview Interview None Interview and Police Report Deposition Subpoena if necessary Argument that the Hoods caused accident by pushing Timothy off of the curb. Damages Will Treatum, M.D. I.M. Nutt, M.D. Timothy Cowling Sandra Cowling Any other treating doctors Police officers Interview and Medical Records Interview and Medical Records Interview Interview and records before and after photos Interviews and records Interviews and records Deposition and subpoena for records if necessary None None Deposition and subpoena for records if necessary Marijuana use and lying to teacher. Previous injury to arm; any residual damage from that?