I am currently working on a legal memo for my paralegal studies course and need some guidance on a complex case we are discussing. I would appreciate your insights on how to approach the legal arguments effectively.

Fact Pattern:

This morning, my supervising attorney tasked me with preparing a legal memo addressing the liability of Red's Tavern in an accident involving our client, Ms. Jane Healy. Ms. Healy, a 32-year-old public relations specialist, was injured when another driver, Charles Raymond, struck her vehicle after being served at Red's Tavern. Raymond, a known repeat DUI offender whose license was suspended, had been drinking heavily at the tavern just before the accident. His employer, Allegretti & Sons, had previously entrusted him with delivery tasks, knowing his history.

The accident resulted in severe injuries to Ms. Healy, compromising her upcoming promotion and her ability to work in public relations. Given the complexity of the case involving multiple parties and contributory negligence, I need to solidify our legal arguments and strategize effectively.

Questions for Guidance:

Case Law Analysis:

• Could you help me find appropriate quotes from these cases that could support our memo?
  • Campbell v. Carpenter, 279 Or. 237, 566 P.2d 893 (1977)
  • Brigance v. Velvet Dove Restaurant, Inc., 725 P.2d 300 (1986)
  • Rappaport v. Nichols, 31 N.J. 188, 156 A.2d 1 (1959)

Statutory Analysis:

• Which Oregon Revised Statute would be most useful for establishing the liability of Red's Tavern, and why? (ORS 471.410, ORS 471.412, ORS 471.565)

Most Supportive Case:

• Based on the provided case law, which case would best support our argument for the liability of Red's Tavern?

Strongest Argument for Our Client:

• What do you see as the strongest argument in favor of our client, Ms. Healy, given the circumstances of the accident?

Potential Weaknesses:

• Conversely, what could be considered the weakest argument against our client?

Additional Defendants:

• Besides the obvious defendants, are there any other parties we might consider adding to the lawsuit to possibly share in the liability?

Key Witnesses:

• Who would be essential to depose in this case to strengthen our position?

Essential Documentary Evidence:

• What types of documentary evidence should we focus on gathering or subpoenaing to support our case?

Legal Strategy:

• Given the circumstances, why might it be more advantageous to pursue a lawsuit against Red's Tavern rather than directly against the driver, Charles Raymond?

Visible Intoxication Signs:

• How might the "50 Signs of Visible Intoxication" from the Oregon Liquor Control Commission play a role in establishing Red's Tavern's liability?

Dram Shop Liability:

• Could you explain "dram shop liability" and how it might apply to Red's Tavern in this scenario?

Respondeat Superior Doctrine:

• How does the doctrine of "Respondeat Superior" relate to this case, especially concerning Allegretti & Sons' responsibility?

Deep Pockets Concept:

• What does the term "deep pockets" imply in the context of this lawsuit?

Judgment Proof Concept:

• What does "judgment proof" mean, and how might it affect our strategy in suing Charles Raymond directly?

Additional Information:

• Lastly, are there any additional details or clarifications in the fact pattern that might be critical for a deeper analysis?

Your expertise and feedback would be greatly appreciated as I navigate this assignment and aim to develop a comprehensive understanding of the legal issues involved.