....CIV PRO TWO
PROBLEM SEVEN

 Table of Contents

Instruction Memorandum .....................................................................................
Pat Plaint's Complaint ..........................................................................................
Motion to Quash [Complaint] ..............................................................................
Interrogatories and Request for Admissions ......................................................
Objections to [IRs & RFAs] Discovery ................................................................
Affidavit in Support of Dan's Summary Judgment Motion ..................................
Motion to Strike [Demand for Jury] ......................................................................
Motion for Judgment or New Trial .......................................................................
Motion for Summary Judgment .............................................................................
Supplemental File
.....Statute: California Code of Civil Procedure Sec. 418.10 ..................................
.....Case: Vons v. Best, California Supreme Court .................................................
.....Deposition Testimony: Plaintiff .........................................................................
.....Trial Testimony: Plaintiff's treating doctor .........................................................

MEMORANDUM of LAW

04/18
To: Junior Associate Clare(nce) Darrow
Fm: Managing Attorney
Re: Pat Plaint Case File Instructions
--------------------------------------------------------------------------------------------------------

We have just substituted into this case as appellate counsel of record for the plaintiff.

Trial has just ended. The trial judge ended this case by granting a Motion for Judgment against the plaintiff, Pat. We have to review this case, by searching the record to determine whether Pat has an arguable basis for appeal. Look for any prejudicial error, but make sure you identify any errors that you can find, so that I can consider those matters which you might characterize as only "harmless" error.

This file contains selected portions of various pleadings and motions, as well as some discovery and trial testimony excerpts. I have also sprinkled in some narrative facts and questions, which I have already thought about, but which I have not resolved. I need your further review to help me make the right choices for our client.

I know that this is your first assignment since coming to the firm. I also know that you probably did not have one quite like it in law school. If you believe in what we are trying to accomplish, however, then I'm sure that you will find this memo useful in your future endeavors at the firm. It is of course my hope that you will perceive this project as not only helpful to a client whom we must zealously represent, under the code of professional ethics, but also a useful indicator of what to epect from the practice of law.

I do not have a particular format in mind. So please concentrate, instead, on the following: the legal issues, the applicable rules of law, the respective arguments (absent a slamdunk for either Pat or the Deli/Widgecorp), and any conclusion which you care to tender. While we represent the plaintiff in this appeal, we do need to see where our weak points are, so that we can best represent the interests of our client.

S. Taskmaster, Managing Attorney
Dewey, Cheatem & Howe

................................................ .............Pleadings/Motions:
................................................San Diego County Superior Court
Pat Plaint, Plaintiff
.............v.
Dan's Deli, Does 1-10, and
Widgecorp, Inc., Defendants
COMPLAINT
Personal Injury
Civil #654321

On May 1, 20__, Pat, a former New Yorker now attending law school in California, purchased a single Edible Widget at Dan's Deli in San Diego, CA. After consuming said Widget, and as a result thereof, Pat became ill and was hospitalized for one week. Pat's medical expenses were $25,000.00.

Edible Widgets are served by Dan's Deli and made by an Oregon food processor named Widgecorp, Inc. (WC). WC sells its refrigerated Widgets to deli's throughout the United States. In addition to this product being dangerous, the defendant's food handling procedures constitute a danger to the public including the plaintiff in this action.

WHEREFORE, plaintiff prays for a judgment ordering the permanent closing of Dan's Deli and reimbursement for all of plaintiff's losses caused by the defendants, the total value of which meets the jurisdictional minimum [$25,000.00] of this court.


Facts: The defendants timely removed this case to the federal court in San Diego. WC had
answered and objected to further proceedings on the basis of a lack of in personam jurisdiction
(IPJ). Pat objected to removal, claiming a lack of subject matter jurisdiction (SMJ).

MOTION TO QUASH
Pat v. Dan's Deli, et al.
Code Civil Procedure Sec. 418.10(a)(1)

Comes now the defendant Widgecorp (WC), who [timely] moves to dismiss Pat's complaint, on the ground that this court has no personal jurisdiction over this defendant.

WC sold only 1/10TH of 1% of its Widgets in California during 1995, exclusively to Dan's Deli in San Diego. After 2004, WC no longer sold any product anywhere in California. Thus, Defendant Widgecorp should not have to defend this action in California.


Questions:
(1) Did the state court have IPJ over WC?
(2) Does the federal court have SMJ?

More Facts: Assume that the court rules that it possesses SMJ. Pat and Dan's
Deli then exchange the following documents:

.....................INTERROGATORIES and REQUESTS FOR ADMISSIONS
...............................................
Pat v. Dan's Deli, et al.

Please take notice that plaintiff Pat hereby submits the following discovery requests to Dan's Deli, pursuant to Rule 33 and Rule 36 of the Federal Rules of Civil Procedure.

Your responses should be submitted to Pat's lawyers within thirty days:

Interrogatories:
1. What information concerning the events in this action has been exchanged between
...Dan's.Deli and Widgecorp?
2. What is the substance of the reports of any experts hired by Dan's Deli regarding
...food-processing requirements?

Request for Admission:
Plaintiff requests Dan's Deli to admit that it stopped serving Edible Widgets when Pat became ill from eating them.

[The defendants' objections to this discovery appear immediately below:]

.....OBJECTIONS TO DISCOVERY
.............Pat v. Dan's Deli, et al.

Dan's Deli objects to Pat's discovery requests on the following grounds:

A. Interrogatories 1 and 2 are privileged.
B. Plaintiff's Request for Admission calls for a response which would be:
.....(a) irrelevant to the issues; and
.....(b) inadmissible at trial.

Question 3: How should the court rule on these objections?

Facts: Dan's Deli then files a motion for summary judgment containing the following document
in support of the defendant Deli's motion:

AFFIDAVIT IN SUPPORT OF DAN'S
SUMMARY JUDGMENT MOTION
.......
Pat Plaintiff v. Dan's Deli, et al.
..........Fed. Rule Civ. Pro 56(c)

Wally Witness, being duly sworn, states as follows:

I am a law student at TJSL. I live near defendant Dan's Deli, where I frequently go to have lunch. I have been there on numerous occasions before and after the events described in the plaintiff's complaint.

On May 1, 20__, I was a patron in Dan's Deli. My classmate, Pat Plaint, and a companion entered the Deli. They ordered Edible Widgets, and sat at a nearby table. I then overheard Pat say to the companion, with unmistakable clarity, "I'm sick of discussing widgets in our lawschool classes--I ought to get sick of Edible Widgets so that Dan's Deli will remove them from the menu. I could make a big splash in legal education if I were the first law student to get sick while attempting to digest a widget. If the Deli refuses to remove Edible Widgets from the menu, I will sue to close the place."

I, Wally Witness, also overheard Pat's companion reply "Hey, what a hypo! We could enter the realm of the rich and famous by implementing your devious plot! It makes me randy!" Pat and the companion then looked at me, lowered their voices, and began to write whatever they were discussing in their notebooks.

__________________
Wally Witness

Sworn and subscribed to before Jumpin' Jack, an authorized Notary Public of the County of San Diego ***.

Question 4: Pat's counter affidavit stated that the remarks overheard by Wally were said in jest.
Should the court grant the Deli's motion?

Facts/Motion: Assume that the court denied the Deli's motion for summary judgment. Pat
timely requested a trial by jury. The defendants filed the following document:

MOTION TO STRIKE
Pat v. Dan's Deli, et al.
Fed. Rule Civ. Pro. 12 (f)

We hereby move the court for an order striking the plaintiff's demand for trial by jury. This is a sham request since the plaintiff has requested equitable relief.


Fact: The court denied the motion to strike.
Question 5: Is there a right to jury trial in this case?



Facts/Motion: The case then proceeded to a trial by jury. During the trial of this action Pat,
and Pat's treating doctor testified regarding Pat's contaminated food claim. The defendants
then testified regarding their food-handling procedures. Their primary trial evidence was that of
Wally Witness--whose testimony was identical to his summary judgment affidavit. The other
key trial testimony--Pat's treating doctor--is presented below, in the Supplemental File.)

The jury held for Pat and awarded Pat $25,000.00. The defendants timely filed the following
document:

........MOTION FOR JUDGMENT OR NEW TRIAL
...........................
Pat v. Dan's Deli, et al.

The defendants now move for a judgment by the court, or in the alternative, for a new trial. The jury's verdict was clearly against the weight of the evidence. The defendants thus pray for a judgment of the court in their favor; or alternatively, for a new trial of all issues.

Question 6: Should the court grant either of these motions? (Do not argue right to jury.)

Facts/Motion: The trial court granted only the defendant's Motion for Judgment against Pat.
There were no appeals. Dan's Deli then filed an action against Pat for damages resulting from a
bad check. This check, dated May 10, 20__, was used to pay for Pat's "tab" at the Deli for the
two dates of April 25th and May 1st of 20__ [same year]. Pat's lawyer, after answering the Deli's
complaint and alleging various affirmative defenses, timely filed the following motion:

.....MOTION FOR SUMMARY JUDGMENT
..........................
Dan's Deli v. Pat

Comes now the defendant Pat, who seeks a summary judgment. The Deli cannot sue Pat since a prior federal action has resolved all issues between these parties.

Question 7: Should the court grant the summary judgment?

SUPPLEMENTAL FILE

This file consists of statutes, cases, and excerpts from certain documents. Read them to
determine what, if any, application they have to resolving the issues presented in Problem 7:

....................................................Statutes:
Calif. Code of Civil Procedure, Section 418.10:
(a) A defendant *** may serve and file a motion for one or more of the following purposes:
.....(1) To quash service of summons on the ground of lack of jurisdiction of the court over him
or her.
..........................................................***
(c) If the motion is denied by the trial court, the defendant, within 10 days *** and before
pleading, may petition an appropriate reviewing court for a writ of mandate to require the
trial court to enter its order quashing the service of summons ***.

........................................................Case:
Von's Companies v. Seabest Foods, Inc.
14 Cal.4th 434 California Supreme Court
December 12, 1996 (citations omitted)

We consider in this case the issue whether California courts may exercise personal jurisdiction over owners of "fast food" restaurant franchises located in another state, in litigation stemming from several incidents of food poisoning that occurred in the foreign jurisdiction. We conclude that the franchisees had sufficient contacts with California through their relationship with their California franchiser, and that the tort claims alleged against the franchisees in a cross-complaint filed in a California action stemming from the food poisoning incidents were sufficiently related to the franchisees' contacts in California, to justify this state's exercise of jurisdiction over the franchisees.

In 1993, customers of *** restaurants in several states, including Washington, suffered from exposure to Escherichia coli (E. coli) bacteria traced to hamburgers sold at the restaurants. *** Foodmaker, Inc. *** is a Delaware corporation with its principal place of business in San Diego, California. It blamed the E. coli contamination on its meat suppliers, including the Vons Companies, Inc. (Vons). Vons processed hamburger patties in its El Monte, California plant and shipped them to Foodmaker for use in *** [the] restaurants.

Vons's cross-complaint alleged the injuries caused by the E. coli contamination would have been avoided had Foodmaker and its franchisees cooked the hamburgers at the proper temperature. Specifically, it alleged Foodmaker, Seabest, and WRMI had failed to follow proper procedures for cooking the meat, and that their procedures were "systematically deficient when measured against industry standards." In addition, it alleged Foodmaker, Seabest, and WRMI had failed to follow government standards for cooking the meat at a proper temperature, that Foodmaker had failed to inform its franchisees of the applicable government regulations, that the "standard" grills used by Foodmaker, Seabest, and WRMI were below the industry norm and lacked various safety features, and that Foodmaker, Seabest, and WRMI failed to require adequate qualifications and training for their cooks.
........................................................***
The trial court granted the motions to quash, and the Court of Appeal affirmed, also ordering Vons to pay Seabest's and WRMI's costs on appeal. We granted Vons's petition for review [and reverse].
........................................................***
California's long-arm statute authorizes California courts to exercise jurisdiction on any basis not inconsistent with the Constitution of the United States or the Constitution of California. A state court's assertion of personal jurisdiction over a nonresident defendant who has not been served with process within the state comports with the requirements of the due process clause of the federal Constitution if the defendant has such minimum contacts with the state that the assertion of jurisdiction does not violate " 'traditional notions of fair play and substantial justice.' "
........................................................***
Personal jurisdiction may be either general or specific. A nonresident defendant may be subject to the general jurisdiction of the forum if his or her contacts in the forum state are "substantial ... continuous and systematic." In such a case, "it is not necessary that the specific cause of action alleged be connected with the defendant's business relationship to the forum." Such a defendant's contacts with the forum are so wide-ranging that they take the place of physical presence in the forum as a basis for jurisdiction. No question of general jurisdiction arises, however, in the case before us.

If the nonresident defendant does not have substantial and systematic contacts in the forum sufficient to establish general jurisdiction, he or she still may be subject to the specific jurisdiction of the forum, if the defendant has purposefully availed himself or herself of forum benefits, and the "controversy is related to or 'arises out of' a defendant's contacts with the forum." It is this type of personal jurisdiction that Vons seeks to establish in this case.
........................................................***
According to the high [US Supreme] court, it is fair to subject defendants to specific jurisdiction, because their forum activities should put them on notice that they will be subject to litigation in the forum. That is, "[w]hen a corporation 'purposefully avails itself of the privilege of conducting activities within the forum State,' [citation] it has clear notice that it is subject to suit there, and can act to alleviate the risk of burdensome litigation by procuring insurance, passing the expected costs on to customers, or, if the risks are too great, severing its connection with the state." This element of fair warning gives "a degree of predictability to the legal system that allows potential defendants to structure their primary conduct with some minimum assurance as to where that conduct will and will not render them liable to suit."

The United States Supreme Court has explained, for example, that a state properly may exercise specific jurisdiction when it " 'asserts personal jurisdiction over a corporation that delivers its products into the stream of commerce with the expectation that they will be purchased by consumers in the forum State' and those products subsequently injure forum consumers. Similarly a publisher who distributes magazines in a distant State may fairly be held accountable in that forum for damages resulting there from an allegedly defamatory story. And in the case of litigation arising out of an ongoing franchise agreement, the high court has found proper a Florida court's exercise of specific jurisdiction over a franchise operator located in Michigan, emphasizing that "parties who 'reach out beyond one state and create continuing relationships and obligations with citizens of another state' are subject to regulation and sanctions in the other State for the consequences of their activities."

A state may exercise specific jurisdiction over a nonresident who purposefully avails himself or herself of forum benefits, because the state has "a 'manifest interest' in providing its residents with a convenient forum for redressing injuries inflicted by out-of-state actors. Moreover, where individuals 'purposefully derive benefit' from their interstate activities it may well be unfair to allow them to escape having to account in other States for consequences that arise proximately from such activities." Further, "because 'modern transportation and communications have made it much less burdensome for a party sued to defend himself in a State where he engages in economic activity,' it usually will not be unfair to subject him to the burdens of litigating in another forum for disputes relating to such activity."

Finally, in analyzing the exercise of specific jurisdiction, "[o]nce it has been decided that a defendant purposefully established minimum contacts within the forum State, these contacts may be considered in light of other factors to determine whether the assertion of personal jurisdiction would comport with ' fair play and substantial justice.' "Courts may evaluate the burden on the defendant of appearing in the forum, the forum state's interest in adjudicating the claim, the plaintiff's interest in convenient and effective relief within the forum, judicial economy, and "the 'shared interest of the several States in furthering fundamental substantive social policies.' "
........................................................***
We conclude that this state may exercise specific jurisdiction over Seabest and WRMI. Indeed, this case closely resembles Burger King, supra, 471 U.S. 462, which, we believe, largely governs the outcome here. As we explain, the cross-defendants here, like the defendants in Burger King, purposefully availed themselves of benefits in the forum by reaching out to forum residents to create an ongoing franchise relationship.
........................................................***

.............................................................Documents:
DEPOSITION OF PAT PLAINT (Paintiff)
(taken by Dirty Dan, counsel for defendants)

***

Q: Well, I don't care what your law school professor said, I'm here to show you what they didn't teach you in lawschool. It's beginning to look like the Widget you had at Dan's Deli did have an impact--strike that, I'm sorry.

A: Yes, you are "sorry."

Q: Getting back to your background, will you be returning to New York to practice law?
Counsel for the Plaintiff: Objection. Irrelevant--has nothing to do with this case.

Q: You've got to be kidding. Tell you what--give me just a few more questions moments and I think we can wrap this case up, o.k.?

Counsel for the Plaintiff: O.k., but make it short.

Q: Pat, you said that you came from New York to go to law school here?

A: That's correct.

Q: And do you intend to return there to practice law after you graduate?

A: No--I think I want to practice here first. Then I'll return home to New York to take the bar there and practice on a permanent basis.

Q: But you'll be here first, for a period of time after you graduate from law school?

A: Yes, that's correct.

Counsel for the Plaintiff: You said that this would be short. Are we done?

Q: Dirty Dan: Well, there was the matter of her injuries. Just two questions, Ms. Plaint. I understand from your pleadings that you were in the hospital for two weeks?

A: That's "affirm." Sorry, been in this Navy town too long. I mean that's correct.

Q: Please describe any pain or discomfort you had while there.

A: Actually, it wasn't that bad. Food poisoning is no fun you know. However, this was the perfect opportunity to catch up on some testing I needed done for some chronic problems I've experienced. Kinda like my 50,000 mile checkup.

Q: Thank you, Ms. Plaint--and I really mean that. Your more than complete answers are much appreciated. I'd also like to thank your counsel, because your respective levels of preparation for this deposition are remarkable!

................................Trial Testimony of Plaintiff's Treating Doctor
...................................................(by P's lawyer on direct exam):

........................................................***

Q: Doctor Kevorkian, now that we have established your background and relationship to this case for the jury, may I just refer to you as "Doctor" in this afternoon's proceedings?

A: Yes, of course.

Q: Now, you were saying that you remember the plaintiff, and the details of her particular condition, when you saw her last year in the hospital?

A: Yes.

Q: How can you be so sure?

A: The elevator music that afternoon was from my favorite band--only time that ever happened!

Q: Your favorite musicians?

A: Yes, the Grateful Dead.

Q: Was Pat Plaint complaining of pain when you first saw her?

A: Yes.

Q: Please explain.

A: She had symptoms consistent with Ratzaphlatzapackalumer Syndrome.

Q: What's that?

A: That is the condition exhibited by routine food poisoning patients. [Further explanation deleted.]

Q: Did Ms. Plaint have this problem for the whole week that she was in the hospital?

A: Oh, no.

Q: How long, then?

A: That afternoon and evening, with minor irritation on the next morning.

Q: Then it's obvious that Dan's Deli was responsible?

By Defense Counsel Dirty Dan: Objection, your honor.

The Court: Any particular reason, counsel, or "just because?"

Q: Because, Your Honor, he's leading his witness. Because, Your Honor, the question calls for speculation. Doctor Kevorkian would not have personal knowledge about where the alleged food poisoning occurred.

The Court: Sustained.

Q: No further questions, Your Honor.  

.....................................Trial Testimony of Wally Witness
........................................(by D's lawyer on direct examination):

*** 

Q: Wally, may I call you that?

A: Yes, please. Even my friends call me that.

Q: Can you tell the jury what you observed at Dan's Deli on the day we have been referring to?

A: On May 1, 20__, I was a patron in Dan's Deli. My classmate, Pat Plaint, and a companion entered the Deli. They ordered Edible Widgets, and sat at a nearby table. I then overheard Pat say to the companion, with unmistakable clarity, "I'm sick of discussing widgets in our lawschool classes--I ought to get sick of Edible Widgets so that Dan's Deli will remove them from the menu. I could make a big splash in legal education if I were the first law student to get sick while attempting to digest a widget. If the Deli refuses to remove Edible Widgets from the menu, I will sue to close the place."

Q: Then what happened?

A: I also overheard Pat's companion reply "Hey, what a hypo! We could enter the realm of the rich and famous by implementing your devious plot! It makes me randy!" Pat and the companion then looked at me, lowered their voices, and began to write whatever they were discussing in their law school notebooks.

Q: No further questions, Your Honor.

The Court: Does P's counsel have any questions for the witness?

By P's Counsel: Yes, Your Honor, just three.

The Court: You may proceed.

Q: Wally, you've testified about what you heard. Did you hear what Pat and Pat's companion actually said, after they went back to writing in their law school notebooks?

A: No.

Q: Isn't it possible that they were just joking about the widget hypo in a humorous context?

A: Well yes, but....

Q: Then you can't testify whether they were actually discussing something other than their law school homework?

A: No, but....

Q: No further questions, Your Honor.


..END OF DOCUMENT
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