Draft a facts statement for our client, Ronnie Randall. Janice Kahn, the plaintiff, brought an action against Randall for intentional infliction of emotional distress. You should prepare your facts statement based on this excerpt from a deposition transcript, witness statements, and a police report. The facts statement will be included in a memo that discusses the issue of intentional infliction of emotional distress. For the purpose of this memo, intentional infliction of emotional distress is defined as follows:

An act by a person that is extreme and outrageous conduct, done with intent to cause another to suffer severe emotional distress, and which results in distress and emotional injury to another. The emotional injury must manifest itself with a physical problem.

Below is a portion of Janice Kahn's deposition transcript re you doing when the accident occurred? In my garden: I planted tomatoes, green peppers, carrots your garden located on your property? rout, near the street. It is next to a brick wall. I can'tsee the en from my house. What direction were you facing in your garden North Does that direction face the street No What do you usually do In your garden when you work Weed it. What were you doing in your garden when the accident occurred Weeding it. Where the street in relation to your garden460 CHAPTER 21 / FACTS About five feet. Q Where do the children A. In the backyard. Q Where were the children playin A. They were playing Tball In Q Were you watching the A Yes I could see them. Q Did you see the accident A. Sort of. Q Did you or did you not I saw my son, who is Il yes and blood all over the front Q Did you actually see the driv A. No. But I know Ronnie bit I heard him swerve. Q Did you know the dra A. Yes. Q How did you know him A. We met at a state fair. We weeks before the accident Q Did he know your son? He knew my son was the most import Kill him to pay me back for dump Are you accusing the driver of A Yes. He wanted to get back What happened to your N.He sustained head injuries ball for the rest of the Dells because he's been Was he conscious shows He was avale, but they where. I knew the ever wasn't even looking sbe street to get my at Did your s down on purpEXERCISES 461 Was your son able to move after the accident? Slightly. He looked just like our neighbor's son did after Ronnie hit him with his car two weeks before at the same curve Police Report, State of Illinois Ronnie Randall, the driver of a 2013 Cadillac, was cited for driving while under the influence of alcohol and/ or drugs, reckless driving, and driving with a suspended license, I will ask the prosecutor to consider either reckless assault charges or vehicular homicide, depending upon the condition of the boy. I tested Randall for alcohol intoxication. His blood alcohol level was .11. Randall struck another boy. Tommy Albert, at the same site two weeks earlier. He was cited for reckless driving for that accident and drunk driving As I arrested Randall, he said that he was daydreaming during the accident and that he did not mean to hit the child. There were no skid marks. The street was dry The boy's mother. Janice Kahn, was working in her garden about five feet from the accident scene at the time of the accident. Her son. Billy Kahn, was playing a game in the street. Witness Statement Two days before the accident, Rhonda Albert, a neighbor of Janice Kahn heard Randall say that he planned to get even with Kahn after Kahn broke off her ten-year relationship with Randall. Albert saw the car strike Kahn's son, According to Albert, after the car struck the boy, Randall got out of his car and said. "Oh. my God. I didn't mean to hit him. Is he okay?" Albert could smell alcohol on Randall's breath Witness Statement Rebecca Mark saw the driver