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LAT 's 7th Annual Technology Survey results reveal more paralegals feel the beat of technology.
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Statistical analysis by
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The latest in trial presentation software, hardware and gadgetry.
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A paralegal's guide to reining in electronically stored information.
By Sally A. Kane

In Good Form
Increasing the Value of Mental and Emotional
Injury Cases
By John D. Winer

Table of Contents

In Good Form

Welcome to Legal Assistant Today's Forms section, featuring free practice-tested forms and advice from veteran attorneys. Each link below provides an easily modifiable Microsoft Word version referenced in the corresponding In Good Form feature. Simply click on the link and the word document is instantly downloaded to your computer.

NOTE: For best results, please use Microsoft Word.

May/June 2008
Increasing the Value of Mental and Emotional Injury Cases
Excerpted from Proving Mental and Emotional Injuries, by John D. Winer

   Pattern Allegations and Complaints

     §5:41 Negligent Infliction of Emotional Distress Zone-of-Danger

     §5:42 Negligence With an “Impact” Requirement

     §5:43 Negligent Supervision of a Child by a Parent

     §5:44 Negligent Supervision by a School

     §5:45 Action for Assault With Respondeat Superior Allegations Against Principal

     §5:46 Action for Battery With Respondeat Superior Allegations Against Principal

     §5:47 Action for Premises Liability Against Business for Sexual Assault

     §5:48 Intentional Infliction of Emotional Distress: Weight-Loss Center Intentionally
               Misrepresenting Nature of Diet Pills

     §5:49 Psychotherapist-Patient Sexual Abuse: Professional Negligence and Intentional Infliction
               of Emotional Distress

     §5:50 Sexual Harassment/Gender Discrimination

     §5:51 Elder Abuse Complaint Against a Nursing Home

   Discovery Documents

     §6:10 Special Interrogatories: Sexual Harassment Case

     §6:20 Requests for Admissions: Age and Sex Discrimination in Employment Case

     §6:21 Requests for Admissions: Sexual Harassment Case

March/April 2008
Pattern Interrogatories for Invasion of Privacy
Excerpted from Model Interrogatories, by Kevin R. Culhane

Forms from Plaintiff to Defendant

     §2517.2.2   Prior Actions for Invasion of Privacy

     §2521         Fact of Intrusion

     §2522         Reasonable Expectation of Privacy

     §2523         Intrusion as Highly Offensive to a Reasonable Person

     §2532         Matter Disclosed as “Private Fact”

     §2533         Disclosure Offensive to a Reasonable Person

     §2534         Disclosure Regarding Matter of Legitimate Public Concern

     §2541         Giving Publicity to a Matter Concerning Plaintiff

     §2542         False Characteristics, Conduct or Belief

     §2542.1      False Light Requiring Reference to Extrinsic Facts

     §2543         Disclosure Offensive to a Reasonable Person

     §2544         Knowledge or Reckless Disregard of Falsity

     §2551         Fact of Appropriation

     §2552         Publication of Matters of Public Interest

     §2571.1      Damage to Reputation

     §2571.2      Economic Losses

     §2571.3      Loss of Goodwill

     §2571.4      Emotional Distress Damages

Forms from Defendant to Plaintiff

     §2517.1.4    Similar Claims and Legal Proceedings

     §2526          Fact of Intrusion

     §2527          Reasonable Expectation of Privacy

     §2528          Intrusion as Highly Offensive to a Reasonable Person

     §2531           Fact of Disclosure

     §2536          Fact of Disclosure

     §2537          Matter Disclosed as “Private Fact”

     §2538          Disclosure Offensive to a Reasonable Person

     §2539          Disclosure Regarding Matter of Legitimate Public Concern

     §2546          Giving Publicity to a Matter Concerning Plaintiff

     §2547          False Characteristics, Conduct or Belief

     §2547.1       False Light Requiring Reference to Extrinsic Facts

     §2548          Disclosure Offensive to a Reasonable Person

     §2549          Knowledge or Reckless Disregard of Falsity

     §2561          Fact of Appropriation

     §2562          Publication of Matters of Public Interest

     §2572.1       Damage to Reputation

     §2572.2       Economic Losses

     §2572.3       Loss of Goodwill

     §2572.4       Emotional Distress Damages

January/February 2008
Obtaining Medical Opinion Evidence for Social Security Disability Hearings
Excerpted from Social Security Disability Practice, by Thomas E. Bush

     §221.8      Letter to Treating Source Transmitting Residual Functional Capacity Questionnaire

     §221.9      Medical Opinion Regarding Physical Capacity for Work

     §221.10    Memorandum: The Role of the Treating Doctor in Social Security Disability
                     Determinations

     §230.3      Chronic Fatigue Syndrome Residual Functional Capacity Questionnaire (short version)

     §231.2      Lumbar Spine Residual Functional Capacity Questionnaire (without onset)

     §231.2A    Lumbar Spine Residual Functional Capacity Questionnaire (with onset)

     §231.3      Fibromyalgia Residual Functional Capacity Questionnaire (without onset)

     §231.3A    Fibromyalgia Residual Functional Capacity Questionnaire (with onset)

     §231.4      Arthritis Residual Functional Capacity Questionnaire

     §231.6      Cervical Spine Residual Functional Capacity Questionnaire

     §233.1      Pulmonary Residual Functional Capacity Questionnaire (without onset)

     §233.1A    Pulmonary Residual Functional Capacity Questionnaire (with onset)

     §234.3      Cardiac Residual Functional Capacity Questionnaire (without onset)

     §234.3A    Cardiac Residual Functional Capacity Questionnaire (with onset)

     §239.9      Reflex Sympathetic Dystrophy/Complex Regional Pain Syndrome Type 1 Residual
                     Functional Capacity Questionnaire

     §258.1      Physical Residual Functional Capacity Questionnaire

     §263.1.1   Manipulative Limitations Residual Functional Capacity Questionnaire

November/December 2007
Pattern Interrogatories for Interference With Business Relations
Excerpted from Model Interrogatories, by Kevin R. Culhane

   Interrogatories From Plaintiff to Defendant:
     §2121.3 Contracts Subject to Conditions Precedent

     §2121.4 Void Contract

     §2121.5 Contract Terminable at Will

     §2121 Existence of Contract

     §2121.2 Unenforceable Contract

     §2122.1 Defendant as the Alter Ego of a Party to the Contract

     §2122.2 Conspiracy Claims Against Other Contracting Party

     §2123 Defendant’s Knowledge of Existing Contract

     §2124.1 Acts or Conduct Inducing Breach

     §2124.2 Conduct Rendering Plaintiff’s Performance More Difficult

     §2125 Causation

     §2126 Damages

   Interrogatories From Defendant to Plaintiff:

     §2131 Existence of Contract

     §2131.2 Unenforceable Contract

     §2131.3 Contracts Subject to Conditions Precedent

     §2131.4 Void Contract

     §2131.5 Contract Terminable at Will

     §2132.1 Defendant as the Alter Ego of a Party to the Contract

     §2133 Defendant’s Knowledge of Existing Contract

     §2134.1 Acts or Conduct Inducing Breach

     §2134.2 Conduct Rendering Plaintiff’s Performance More Difficult

     §2135 Causation

     §2136.1 Past Economic Losses

September/October 2007

Litigating Employment Discrimination Cases

Excerpted from Litigating Employment Discrimination Cases, by Andrew H. Friedman

Draft Complaints

5B -1 Americans with Disabilities Act and the Family and Medical Leave Act

5B-2 Age Discrimination and Retaliation

5B-3 Qui Tam Action

5B-4 State Sexual Harassment and Related Actions

5B-5 42 United States Code §1983 Sexual Harassment

Four Sample Demand Letters

10A-1 Demand Letter (Sample Form 1)

10A-2 Demand Letter (Long Form)