DRAFTING A FACTS STATEMENT 15. Draft a facts statement for our client Ronnie Randall. Janice Kahn, the plaintiff, brought an action against Randall for intentional inflicton 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 (What were you doing when the accident occurred? (Working in my garden: I planted tomatoes, green peppers, carrots and broccoli. Where is your garden located on your property? In the front, near the street. It is next to a brick wall. I can't see the garden from my house Q What direction were you facing in your garden? A. North Does that direction face the street? A. No. ( What do you usually do in your garden when you work A. Weed it. ( : What were you doing in your garden when the accident occurred A Weeding It. 0 Where is the street in relation to your garden