Using the case below, form a detailed and extensive memorandum. The memorandum should have included these parts -

Objective Of Assignment:

Statement Of Facts:

ISSUE:

BRIEF ANSWER:

ANALYSIS:

Counteranalysis:

Conclusion:

Recommendations:

MEMO THREE Rhonda versus Lyber

Lyber car services provide rides to customers all over Meander, California. They do a significant volume of business, providing long and short rides. Unlike other companies, their drivers are employees. Lyber charges its customers a little more, but it pays its drivers $15 an hour with benefits. Their motto is "Pay a little more and receive a much higher standard of service." Customer surveys show that the riding public likes Lyber's employment policies.

To use the car service, a person must download the app onto a smartphone. Lyber's app does not support screen reading software. A customer cannot order a ride through a phone call. To contact customer service, a person must use the application, and a Lyber agent calls back. This procedure is similar to that used by other corporations like Amazon.

Rhonda has used Lyber's services in an emergency. Rhonda is blind. She depends on screen reading software for her cell phone and computer. Since Lyber's app does not interface with screen reading software, she must rely upon others to arrange her pick up and destination. Rhonda feels that being forced to depend on others for such a simple task is humiliating and degrading. Last week, Rhonda's carpool had a flat, and they could not pick her up on the way to work. She needed a ride. She wanted to use Lyber's services but could not use the app on her phone because it does not interface with screen reading software. She tried calling everyone she knew to help her, but no one was available.

Meanwhile, Rhonda had a meeting at work scheduled for 10 in the morning. She tried calling the office and could not reach anyone during the commuter hour. When Rhonda finally contacted a person at work, it was 9:15 AM. There was no way she would be able to make it in time for the meeting. Rhonda's boss, Bobbie at Emity Inc., was irritated. Although he called the car service for Rhonda, he wrote Rhonda up for being late. Rhonda's pay was docked an hour and a half for being late, and the write- up was placed in her employee record. Emity has a strict policy against tardiness and regularly deducts the time from employees that arrive late to work. If an employee is regularly late, they may be fired.

Rhonda is distraught and has contacted our office law office for assistance. We know that there have been cases about what is and is not a place of public accommodation and whether a computer application that is a gateway to that place of public accommodation may be liable for discrimination. Similarly, recently we read that there is a split among the different Circuit Courts.

Research the issue and prepare a memorandum stating your findings. Be sure to include each element of a cause of action we would be required to show in order to succeed on an American With Disabilities Claim in this situation.

* Compose a detailed outline.