Fictional matter — created for portfolio demonstration. No real parties, courts, or facts.
memo plaintiff

San Bernardino County Superior Court

Reyes v. Pacific Western Logistics, Inc., et al. · No. CIVDS2401847 (FICTIONAL)

Conflict-of-Interest Check Memo

2024-06-22

[ATTORNEY NAME — STATE BAR NO. ######]
[FIRM NAME]
[ADDRESS LINE 1]
[CITY, STATE ZIP]
[PHONE | EMAIL]

PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION
WORK PRODUCT — DO NOT DISCLOSE

CONFLICT-OF-INTEREST CHECK MEMO

To: [SUPERVISING ATTORNEY]
From: [PARALEGAL NAME]
Date: June 22, 2024
Re: Conflict Check — Maria Reyes v. Pacific Western Logistics, Inc., et al.
File No.: REYES-2024-001 (FICTIONAL)

I. PURPOSE

This memo documents the results of the firm’s conflict-of-interest screening conducted in connection with the proposed representation of Maria Reyes in a personal-injury matter arising from a commercial vehicle collision on November 4, 2023. The check was performed pursuant to California Rules of Professional Conduct, rule 1.7 (Current Clients) and rule 1.9 (Former Clients).

II. PARTIES SCREENED

The following names were entered into the firm’s conflict-checking database and cross-referenced against all current and former client files:

PartyRoleSearch Terms Used
Maria Elena ReyesPlaintiff / Proposed Client”Reyes, Maria”; “Reyes, Maria Elena”
Pacific Western Logistics, Inc.Defendant — Corporate”Pacific Western Logistics”; “Pacific Western”
John DoeDefendant — Individual Driver”Doe, John”; “Doe” (with occupation filter: trucking/logistics)
DOES 1–50Unnamed DefendantsN/A — will re-screen upon identification

III. SEARCH RESULTS

A. Maria Elena Reyes

Result: NO MATCH

The name “Reyes, Maria” returned [##] entries in the database. Each entry was individually reviewed. None of the matches correspond to the proposed client Maria Elena Reyes of Rancho Cucamonga, California, based on date-of-birth cross-reference and address history. No prior representation.

B. Pacific Western Logistics, Inc.

Result: POTENTIAL PARTIAL MATCH — RESOLVED AS NO CONFLICT

The search returned one entry: “Pacific Western Transport LLC” — a company represented by this firm in an unrelated commercial contract dispute in [YEAR — REDACTED]. After reviewing the prior file, [PARALEGAL NAME] confirmed the following:

Conclusion: No disqualifying conflict. However, per firm policy, this finding is being flagged for supervising attorney review and acknowledgment.

C. John Doe (Driver)

Result: NO MATCH

The generic name “Doe, John” returned multiple entries, all of which are court-standard placeholder names used in prior complaints filed by this firm. No conflict. Upon identification of the actual driver’s legal name through service of process or discovery, a supplemental conflict check will be performed.

D. Tangential Relationship Note

In reviewing the prior matter file for Pacific Western Transport LLC, [PARALEGAL NAME] identified that [UNRELATED CLIENT — REDACTED], a former client of this firm in a separate personal-injury matter, was employed by a company that contracted Pacific Western freight services at the time of that representation. This relationship is tangential — [UNRELATED CLIENT — REDACTED] was not adverse to any Pacific Western entity and the subject matter is wholly unrelated. Nevertheless, this finding is disclosed to supervising attorney for determination under CRPC rule 1.7 as a matter of professional judgment.

Supervising attorney acknowledgment required: ______________________

IV. CONCLUSION AND CLEARANCE

Based on the search results documented above, no disqualifying conflict of interest has been identified that would preclude this firm’s representation of Maria Elena Reyes in this matter. The partial match identified in Section III.B has been resolved. The tangential relationship in Section III.D is disclosed for attorney review.

Cleared to open file: [ ] Yes [ ] No (see attorney note below)

Attorney acknowledgment: _______________________ Date: _____________
[ATTORNEY NAME — STATE BAR NO. ######]

V. RETENTION INSTRUCTIONS

This memo shall be retained in the permanent client file. If the identity of Defendant JOHN DOE is ascertained, a supplemental conflict check shall be performed and documented as an addendum to this memo within five business days of identification.

Prepared by: [PARALEGAL NAME]
Date: June 22, 2024

How this was made

Method

Ran adverse-party name list through firm conflict database export; Claude summarized the database query results and formatted match/no-match findings into a clean memo; paralegal reviewed each potential match individually against original file records.

Human judgment points

  • Determined that a 'Pacific Western Transport LLC' entry in the conflict database was a distinct entity from Pacific Western Logistics Inc. and did not constitute a disqualifying conflict — required reading underlying matter files to confirm separate ownership
  • Elected to flag the prior representation of [UNRELATED CLIENT — REDACTED] whose employer used Pacific Western freight services as a tangential relationship requiring disclosure to supervising attorney, even though no direct conflict existed
  • Decided the conflict check memo should remain in the file permanently and not be merged with the intake memo, preserving the chain of documentation required by California Rules of Professional Conduct rule 1.7

Time

~0.5 hours AI-augmented vs ~1.5 hours traditional database review and memo drafting