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Assume that you were a paralegal working for associate in a law firm and you have been tasked with one of the below internal memo assignments.
If your last name starts with J to Z, please complete the following research and writing task:
Review the fact pattern from Week 4 dealing with Mr. Varney’s daughter who was bitten by a dog in New York. Assume that Mr. Varney, a citizen of Alabama, filed a complaint in the United States District for the Southern District of New York based on diversity of citizenship against the dog owners, who are citizens of New York, and the hotel, owned by a corporation with headquarters in Delaware. Assume that you are working for a law firm that is representing the dog owners. The dog owners have asked you to file a motion for summary judgment. Please assume the United States District for the Southern District of New York possesses personal and subject matter jurisdiction.
Do some research into the standard of review that the district court judge will apply when evaluating the dog owners’ motion for summary judgment. Locate the applicable cases and Rules of Civil Procedure that the district court judge may review when making his or her decision on the motion for summary judgment. Then, provide outline what additional information, you would need to learn about the complaint to assess whether to file the motion for summary judgment on behalf of the dog owners. Organize your findings and recommendation in the form of a short internal memo.
All students: In preparing your short memo, please use the following memo as an example:
CUNY Law Office Memo Example (will provide this link later)
Be sure to cite your sources using proper Bluebook format. Please note in the body of the memo if we need to locate any additional information to assess the situation. Also, please remember that all parts of the memo must relate to the facts of the fact pattern.
If you have any questions about how to draft your memo, please remember that I am here to help. Also, note that this memo assignment is different from the prior week’s assignment because it asks you to specifically identify the applicable Rules of Civil Procedure relevant to the fact pattern. And remember that you shouldn’t spend more than a few hours working on this internal memo assignment.
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