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

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

CLIENT INTAKE MEMO

To: [SUPERVISING ATTORNEY]
From: [PARALEGAL NAME]
Date: June 20, 2024
Re: Maria Reyes — Potential Personal Injury Matter — Commercial Vehicle Collision
File No.: REYES-2024-001 (FICTIONAL)

I. INTAKE SUMMARY

This memo documents the initial intake call conducted on June 18, 2024, with Maria Reyes (“Client”), a 38-year-old licensed vocational nurse (“LVN”) residing in Rancho Cucamonga, California. Client was referred by [REFERRAL SOURCE — REDACTED]. The call lasted approximately 55 minutes. Client executed a telephonic consent to record; recording is archived at [INTAKE FILE PATH — REDACTED].

Client is seeking representation in connection with a motor-vehicle collision that occurred on November 4, 2023, on Milliken Avenue at the I-15 interchange in Ontario, California, in which a semi-truck operated by an employee of Pacific Western Logistics, Inc. struck her vehicle broadside while she was proceeding through a green light.

II. PARTIES IDENTIFIED

III. FACT CHRONOLOGY

November 4, 2023 — Collision Event

Client states she was driving westbound on Milliken Avenue at approximately 7:15 a.m., traveling to her shift at [FACILITY NAME — REDACTED]. She entered the intersection on a green traffic signal. A fully-loaded semi-truck traveling northbound on the I-15 off-ramp ran the red light and struck her 2019 Honda Civic on the driver’s side at what she estimated was “full highway speed.” Client did not see the truck brake before impact. She recalls hearing no horn.

Client was transported by ambulance to Arrowhead Regional Medical Center Emergency Department. She was admitted and remained for approximately eight hours before discharge with a cervical collar and instructions for follow-up with her primary care physician.

November 2023 — February 2024 — Initial Treatment

Client was seen by her primary care physician on November 8, 2023. Referring physician ordered MRI studies. January 22, 2024 MRI results confirmed C5-C6 and L4-L5 disc herniations. Client began a physical therapy regimen in February 2024 — three sessions per week for approximately ten weeks initially.

February 2024 — Present — Ongoing Treatment and Work Absence

Due to lifting restrictions imposed by her treating physicians, Client has been unable to return to her LVN position. Her employer at [FACILITY NAME — REDACTED] placed her on unpaid medical leave as of November 7, 2023. She has been receiving short-term disability benefits but states those benefits do not fully compensate for her lost earnings. As of the intake call, her treating physicians have advised that surgical intervention at the L4-L5 level is a possibility if conservative treatment does not achieve further improvement.

IV. LIABILITY HIGHLIGHTS

1. Red-light violation. Client states she was traveling on a green signal; eyewitness accounts at the scene corroborate this according to a California Highway Patrol collision report (copy to be obtained).

2. Employer liability / vicarious liability. The driver was operating the semi-truck in the course and scope of his employment with Pacific Western Logistics, Inc. Respondeat superior doctrine likely applicable.

3. Negligent entrustment. Client reports that a bystander at the scene told her the driver appeared fatigued and disoriented after impact. This is currently unverified hearsay — investigation warranted.

4. FMCSA Hours-of-Service potential violation. Client obtained information from a source (identity unconfirmed — do not record) indicating the driver had been behind the wheel for approximately 14 hours in the 24-hour period preceding the collision. If confirmed, this constitutes a potential violation of 49 C.F.R. § 395.3 (maximum driving time for property-carrying drivers). Driver logs and Electronic Logging Device (“ELD”) data must be requested immediately and preserved.

5. ELD / ECM data. Federal regulations require commercial carriers to maintain ELD data. Litigation hold letter should be sent to Pacific Western Logistics immediately to preserve electronic records.

V. DAMAGES SUMMARY

Note: Client has a CCP § 425.11 Statement of Damages obligation prior to entry of default — anticipate serving this document on defendants promptly after complaint is filed.

VI. CONFLICTS CHECK STATUS

Conflicts check to be conducted by [PARALEGAL NAME] per standard firm protocol. See separate Conflict-of-Interest Check Memo. No known conflicts identified at this stage.

VII. STATUTE OF LIMITATIONS

California Code of Civil Procedure § 335.1 provides a two-year statute of limitations for personal injury claims. Collision date: November 4, 2023. Limitations deadline: November 4, 2025. Complaint should be filed no later than August 1, 2024 to allow service within the limitations period with margin.

VIII. RECOMMENDED NEXT STEPS

1. Send litigation hold / spoliation prevention letter to Pacific Western Logistics, Inc. within 48 hours.
2. Order CHP collision report (Form 555) and all supplemental reports.
3. Obtain complete medical records from Arrowhead Regional Medical Center, treating physicians, and physical therapy provider.
4. Request authorization from client to obtain employment records from [FACILITY NAME — REDACTED].
5. Conduct conflicts check — see separate memo.
6. Prepare draft complaint for attorney review (negligence, negligent entrustment, vicarious liability, loss of consortium if applicable).
7. Investigate potential FMCSA violation; consult trucking liability expert consultant.

Prepared by: [PARALEGAL NAME]
Supervising Attorney: [ATTORNEY NAME — STATE BAR NO. ######]