(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/personal injury case and its proceedings.) THERE EXISTED A SPECIAL RELATIONSHIP BETWEEN THE GREENES AND PLAINTIFF AND PLAINTIFF’S FIRST AND SECOND CAUSES OF ACTION FOR NEGLIGENCE AND NEGLIGENT…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) Thus, it is not unusual or atypical that the extent and nature of these emotional conditions was not discerned as part of…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) SUMMARY OF FACTS This is an action for damages for wrongful death brought by the personal representative of the Estate of Claudia…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) Plaintiff’s Opposition to Defendants’ Demurrer to Plaintiff’s Second Amended Complaint MEMORANDUM OF POINTS AND AUTHORITIES SUMMARY OF ARGUMENT This is an action…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) Dr. Everstine has diagnosed the following emotional and psychological injuries secondary to the subject incident: 1) Paul Smith: PTSD; anxiety; major depression;…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this workplace discrimination/sex harassment case and its proceedings.) iii. The harassment was severe and pervasive, The harassing conduct by Plaintiff’s supervisor is severe and pervasive enough to alter the terms…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/personal injury case and its proceedings.) PROCEDURAL HISTORY Plaintiff filed a lawsuit on May 1, 2007, against the Estate of Danny Smith and Richard Smith, Case No. SC2007-09,…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this workplace discrimination/sex harassment case and its proceedings.) i. Unwanted harassment because of her pregnancy/disability: Plaintiff was subject to abusive conduct because of her pregnancy. Verbal harassment by itself can…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) Dr. Everstine has opined that this treatment is reasonable, necessary and causally related to the subject incident. Dr. Everstine opines that, “each…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this workplace discrimination/sex harassment case and its proceedings.) iii. The termination reasons are false which establishes pretext as well Pretext can be shown by showing the termination reasons are not…