Robinson, Reese & Hodges Memorandum

To: Georgia Hodges, Senior Partner

From: Philip J. Velez, Student Representing JIT

RE: Discovery Plan

This discovery plan is intended to investigate JIT’s knowledge of the events on the night of
September 29, 2009. JIT must prove that it had no intimate knowledge of the Animal House
event at the ZMu fraternity house. JIT must also prove that its admissions and housing policies did
not increase the risk of harm to Brian Sachs by not providing on-campus housing. JIT must prove
that JIT acted with due care and diligence during ZMu’s affiliation with JIT and on the night of
September 29, 2009.
Legal Facts to be Type of Source Discovery FRCP
Elements of Proved/Disprove Evidence Mechanism Provision
Claim d
Against JIT
Negligence/Con Brian Sachs previous High School Albert Sachs, Request for FCRP
tributory history regarding and JIT Sarah Sachs, Deposition 34/30/29
Negligence alcohol and/or drug disciplinary JIT records,
abuse records; contact from
request to Brian Sach’s
depose family high school
members/frien administrators/t
ds eachers

Knowledge/Bre ZMu’s history of JIT disciplinary JIT Request for FCRP

ach of Duty to alcohol/drug record of all Student/Greek Deposition, 34/30/29
Protect violations fraternities Association, production of
JIT, JIT documents
Legal Facts to be Type of Source Discovery FRCP
Elements of Proved/Disprove Evidence Mechanism Provision
Claim d
Against JIT
Knowledge/Bre Disprove JIT’s Correspondenc JIT Admissions Request for FCRP 34
ach of Duty to encouraging Brian e (both paper Office, the Deposition,
Protect Sachs to join and electronic) Sachs family, production of
ZMu/campus between JIT Brian Sachs’ documents
fraternity; and Brian high school
Sachs from and
during his
senior year of
high school
and his initial
pledge to join
ZMu

Breach of Duty JIT’s housing policy JIT’s housing JIT Request for FCRP 34
to did not unreasonably policies, production of
Protect/Causati expose Brian Sachs statistics of documents
on to the events that incoming
caused his death. freshman on-
campus and off
campus-
housing

Knowledge/Bre JIT’s knowledge of Promotion JIT Request for FCRP 34

ach of Duty to the Animal House material for Student/Greek production of
Protect event event (paper Association, documents
and electronic) JIT, ZMu

Causation/Kno Brian Sachs death Medical Hospital Request for FCRP 34/30
wledge/Duty to was a result of Records records, Brian production of
Protect alcohol poisoning Sachs documents
doctor/insurance
company

Egregious Failure to render Campus Police Campus Police Request for FCRP 34
Negligence adequate care to incident report Deposition,
Brian Sachs on the production of
night of September documents
29, 2009