Hi, need to submit a 250 words paper on the topic Week 11 IND WORK. Week 11 IND WORK of Week 11 IND WORK Memorandum Attorney RE: Our Client: Joseph Delgado/ Joseph Vs Pharmaceutical Company Statement

Hi, need to submit a 250 words paper on the topic Week 11 IND WORK. Week 11 IND WORK of Week 11 IND WORK Memorandum Attorney RE: Our Client: Joseph Delgado/ Joseph Vs Pharmaceutical Company

Statement of Fact

This memo addresses the applicable laws and facts concerning to our client, Joseph Delgado, who got injured in the previous year while he was conducting audit work in the main office and the laboratories of the BioMed Pharmaceutical, Inc. However, the company claimed that the work concerning to the security and maintenance of the building is the responsibility of the 2 independent companies and refused to provide any liability to our client for his injuries (Kerley, Banker Hames & Sukys, 2012).

Issue Presented

According to the Worker’s Compensation law, claim of our client that the claim of the company for not providing liability is fair?

Brief Answer

Probably not, however not liability in case of the negligence of our client is fair. There are many cases that support our client’s claim are present. One case is Matrix- Churchill v. Springsteen.


For preparation of any trial the trial notebook is an essential part. Usually it is the responsibility of the legal assistants (paralegals). Basic sections of the trial note book for this case is as follows.

In this case, Joseph Delgado is the plaintiff who raised the claim against the BioMed Pharmaceutical, Inc. Plaintiff works as a certified public accountant in the BioMed Pharmaceutical, Inc. Plaintiff’s attorney for trial is Laura Broke. Her address is Popson, Pierce, Rueber, and Burke Attorneys at Law 5293 St. Clair Avenue Montgomery, Alabama 36101 (205) 725-8788 [facsimile number].

The plaintiff raised the claim that the pharmaceutical company is responsible for his injuries and the claim of the company is wrong.

Plaintiff witness includes Maria Mendez, she is secretary, and employed in the Bio-Med Pharmaceutical, Inc.

Carl Logia is an expert witness for the plaintiff, who is the former employee of the same company.

The document of the trial includes the facts which shows that both the companies i.e. Rawlings Maintenance Cooperation and diversified Security Solutions are the close friends of the defendant company.

For this plaintiff provide the summary which shows that defendant pharmaceutical company owns entire finance and stock of both the companies.

In chronology of this case whole detail of the period of plaintiff’s case is included i.e. the dates of accident, therapy and his returned to work.

Characters includes in this case are. Joseph Delgado the plaintiff, defendant pharmaceutical company, Rawlings Maintenance Cooperation and diversified Security Solutions (supporter of the defendant), plaintiff witnesses Carl Logia, Maria Mendez and some others.

There are many cases for supporting the plaintiff’s claim, some of these are. Matrix- Churchill v. Springsteen, Kwick Set Component, Inc. v. Davidson Industries, Inc.

In this case the trial exhibit includes the length or type of the plaintiff’s treatment.

The jury should include white-collar and well educated person.

Trial outline is an important part of the trial notebook. This section of the trial notebook includes entire detail of the case.

After the trial a page for the notes of attorney is left blank, where attorney can writes notes regarding the case.

The last part of the trial notebook contains the information regarding the tasks that would be required for the trial and checklist preparation.


As in this, the accident is not caused by the negligence of our client but it was an accident that was caused by the negligence of the security and maintenance companies. Therefore because of the convincing claim of our client would be deemed by the court.


Kerley, P., Banker Hames, J. J., & Sukys, J. P. (2012). Civil Litigation Sixth Edition. Clifton Park, NY: Delmar Cengage Learning.

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