Internal Memorandum

To refresh your memory of the Ann C. Dorite case, review her interview and your summary of her interview from module 02. For this assignment you just came out of a meeting with the partners of your firm, Susan & Winem. The meeting was short, but its contents were recorded by the partner’s secretary, Betsy M. Akurate, and she states that she will transcribe the meeting and provide a verbatim transcript.

The firm’s partner, Rich N. Moore, asks you to stay after the meeting. He then asks you to write an internal memorandum with two parts. He specifically states that he wants you to submit the memorandum in one Word document to him and he will circulate to the other attorneys.

The first part of the internal memorandum, Mr. Moore tells you, should be a summary of the meeting you just attended. He says Ms. Akurate will email you the transcript of the meeting.

For the second part of the internal memorandum Mr. Moore wants you to read statutes and cases for Ms. Dortie’s case. He is concerned that since the client was walking in the street the city had no legal duty to maintain the streets in a reasonably safe condition.

Partner Moore tells you that the memorandum (i) should be no more than 4 pages as he has no time to read more than 4 pages; (ii) should only discuss the case authority he will give you; (iii) should update the cases and provide him with the citation to the most recent Illinois case on the subject of pedestrian use of roadways with a 1-2 sentence statement of what the rule of law in the case; (iv) should frame the issue in the second half of the memorandum for the Dorite case using the 123 Method; and (v) should provide a list of points and authorities at the end of your memorandum.

Partner Moore’s secretary, Ms. Akurate, then sends you a memo with the following information:

Read as background and include in your list of points and authorities but not discuss in your memoranda the following statutes:
a. 745 ILCS 10/3-102 (2015); 
b. 740 ILCS 130/2 (2015); 
Read and discuss only the following cases:
Curatola v. Niles, 154 Ill.2d 201, 608 N.E.2d 882 (1993); 
Gutstein v. City of Evanston, 402 Ill. App.3d, 929 N.E.2d 680 (App.Ct. 2010); and 
Vaugh v. City of W. Frankfort, 166 Ill.2d 155, 651 N.E.2d 1115 (1995)

The memo concluded by saying if you had any questions or wanted to clarify the directions you should contact Mr. Moore’s partner Dan Walker by email as Mr. Moore will be out of town for the next week. She also reminded you attorney Moore likes a table of points and authorities at the end of the memo so he can put in the file for quick reference.