Interrogatories

UNITED STATES DISTRICT COURT
DISTRICT OF COLORADO – DENVER DIVISION

Samuel SMITH,
on behalf of himself and all other similarly situated,
Plaintiff,
v.
ACME Corporation
Defendant.
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Plaintiff, Samuel Smith, acting by and through his attorney, Ace Attorney, brings this class action complaint against the Defendant, Acme Corporation, on behalf of herself and a class of similarly situated persons. Smith alleges the following upon information and belief:
1. Acme has shown itself to have no limits in its quest to make a profit
2. Despite knowing that its manufacturing process produces a toxic by product that must be disposed of in a manner that does not contaminate its vitamin products, and does not pollute the environment, Acme knowingly implemented new production procedures which:
(a) violated federal and state regulations that required it to safely dispose of the toxic by-product of its manufacturing process when it discharged the toxic waste into a dry streambed that allowed the waste to contaminate the ground water beneath it and poison hundreds of residents of the nearby suburb of whose source of water is the contaminated groundwater, and
(b) violated its own prior safety procedures and allowed the toxic by-product to contaminate its vitamin products which were subsequently shipped and sold to hundreds of customers across the nation.
PARTIES
1. At all times hereinafter mentioned, Plaintiff was and still is Samuel Smith [adult], and maintains his principal place of residence as the State of Nevada. Smith purchased a bottle of Acme Corporation’s vitamin pills, form a local health store, and within four hours after taking a vitamin from the bottle collapsed and died.
2. At all times hereinafter mentioned, Defendant, Acme Corporation, was and still is a Delaware corporation and maintains its principal place of residence at Denver, Colorado.
JURISDICTION and VENUE
3. This Court has jurisdiction to hear this case based upon 28 U.S.C. Section 1332(d)(2), because the proposed class has more than 100 members, a majority of the class members are citizens of this state, the class contains at least one member of diverse citizenship from Acme Corporation, and the amount in controversy exceeds U.S. $5 million.
4. Venue is properly placed in this court based upon 28 U.S.C. Section 1391 (b)(1), because Acme Corporation resides in this judicial district, and under 28 U.S.C Section 1391 (b)(2), a substantial part of the circumstances and events of the giving arise to this controversy occurred in this judicial district.

FIRST COUNT
1. Plaintiff alleges and incorporates by reference the allegations contained in the foregoing paragraphs of the complaint.
2. Despite knowing that its manufacturing process produces a toxic by product that was harmful to the environment, Acme Corporation knowingly discharged the toxic by product into the dry streambed above a ground water system that was the source of water to a nearby Denver community.
3. By discharging the toxic by product into a dry streambed, contaminated the ground water beneath it and poisoned hundreds of residents of the nearby suburb of whose source of water is the contaminated groundwater, causing severe and permanent damage to the digestive systems of the affected victims.
3. Acme Corporation did this despite being required by federal and state laws to take the appropriate measures to dispose of the toxic by product in a manner that it did not pollute the environment.
4. Acme Corporation knowingly changed its disposal procedures to evade disposal requirements in order to reduce costs and increase profits.
SECOND COUNT
1. Plaintiff alleges and incorporates by reference the allegations contained in the foregoing paragraphs of the complaint.
2. Despite knowing that its manufacturing process produces a toxic by product that must be disposed of in a manner that does not contaminate its vitamin products, Acme Corporation knowingly discontinued those safety and protection procedures.
3. As a result, its vitamin products were contaminated with the toxic by product.
4. Those contaminated vitamins where then shipped and sold to customers around the nation including customers in the state of Nevada.
5. Samuel Smith, a resident of Nevada, died soon after purchasing and eating a contaminated Acme Corporation vitamin. According to his autopsy, there is a possibility that Smith’s death is linked to his consumption of the contaminated vitamin.
6. After this incident, the Food and Drug Administration ordered Acme Corporation to recall the contaminated vitamins
7. According to the Centers for Disease Control, a large number of other purchasers of the contaminated Acme Corporation vitamins also became ill and/or died after consuming them.
PRAYER FOR RELIEF
WHEREFORE, plaintiff, Samuel Smith, demands judgment against the defendant, Acme Corporation, as follows:
A. On the First Count, economic and compensatory relief in amounts to be determined at trial, plus
interest at the maximum rate allowed by law; attorney’s fees and costs; and any such further relief availa under all applicable state and federals laws, and/or what the court may find reasonable.
B. On the Second Count, economic and compensatory relief in amounts to be determined at trial, plus interest at the maximum rate allowed by law; attorney’s fees and costs; and any such further relief available under all applicable state and federals laws, and/or what the court may find reasonable.
DEMAND FOR JURY TRIAL
Plaintiff, on behalf of himself and the proposed class, hereby demands a trial by jury as to all matters triable.

Respectfully submitted,
Holton & Holton
By: Jennifer Holton Esq.
411 Link Avenue
Denver, CO 12345
(201) 506-8874

WEEK 2 ASSIGNMENT

MEMORANDUM
TO: Michele Robinson Esq.
FROM: Tiffany Green
DATE: August 26, 2019
SUBJECT: Saving a form in AbacusLAW
The first step is to ensure that one has access to AbacusLaw by having log in credentials. Once logged in, the graphical user interface in the application has an “intake” button which when clicked shows the different types of forms available. The forms are further broken down into specialty areas such as constitutional and intellectual property law — the appropriate selection has to be made to make work easier in subsequent stages. Nonetheless, if a distinct area of specialty lacks, one can still choose a standard form provided by the proprietor.
The forms are broken down into sections. The first item to be filled concerns details of the case at hand. Some of the information required in this step includes the court litigating the issue and the case number. The second segment requires the filling of contact details of both the client (s) and the counterparty (s). Typing in the details at this point is crucial as it prevents the attorney from having to make repeated entries as the case progresses. It also ensures convenience as the counsel does not gave to keep entering information about a client if they are to retain the client even in different cases. After the contacts parts, one is required to fill in all other available fields in the form.
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