FACTS

Jamie, an employee at Paint Co., was severely injured when he fell from the top step of 10 foot ladder while painting the Nguyen's roof. Jaime was not using thesafety harness provided by Paint Co. or any other restraint system but he was wearing a helmet. Jamiehas a concussion and has no memory of the incident. Leading up to the day of accident, Jamiehad worked 12-hour shifts for 6 consecutive days.

Paint Co. has a published ladder inspection policy, but there is no evidence that the ladder Jamie was standing on has ever been inspected. They also have a published worksite supervisor policy.

Zara, another painter witnessed Jamie's fall from about five feet away and called 911. Two emergency technicians responded to the call, stabilized Jaime, and took him to the emergency room. A nurse examined Jamie and sent him home with an ice pack and a neck brace. Damien, the crew supervisor, was not present at the time of incident but he returned shortly after. When he arrived he took pictures of thescene.

Question:

We represent Paint Co. Jaime's lawyer has sent us a demand letter Links to an external site.. They will file a civil complaint unless Paint Co. agrees to pay Jamie's medical bills, attorney fees, lost wages, and $150,000 in pain and suffering. In return, Jaimie will agree to waive all related future claims against Paint Co. We have 48 hours to answer. Please respond to me with your detailed plan to investigate this matter and determine whether we should settle. What witness will you speak to? What major topics will you address with each witness? What other investigative actions will you take? How will you document your efforts?