Statement of Facts for the salon memoStatement of Facts para el memo del salón

Assignment

Write the Statement of Facts for the salon memo in 250 to 350 words. Use only the facts given in the companion exercise, plus these details: the reviews ran from January 10 to February 21; the calls were between March 1 and March 14; Renata saw her doctor on March 20; Kyle left the salon on December 15 after a dispute over unpaid commissions; Renata has asked whether she can sue Kyle for intentional infliction of emotional distress.

Model answer

Our client, Renata Solís, owns a hair salon in Plano, Texas. She has asked whether she can bring a claim for intentional infliction of emotional distress against Kyle Benner, a former employee.

Kyle worked at the salon as a stylist until December 15, 2025, when he left after a dispute over unpaid commissions. Between January 10 and February 21, 2026, twenty-two one-star reviews of the salon appeared on two review sites under different account names. The reviews stated that Renata “burns clients,” “steals tips,” and “runs an unlicensed salon.” Some of the reviews also included statements of opinion about the salon’s atmosphere and prices. Renata believes Kyle wrote all of the reviews; she has been able to connect several of the accounts to Kyle through a shared profile photograph and an email address, but not all of them. During the same period the salon’s bookings fell by about one third.

Between March 1 and March 14, 2026, Renata received eight calls on her personal cell phone between midnight and 2 a.m. The caller hung up each time without speaking. The calls came from a number Renata recognized as Kyle’s. No threats were made.

Since February, Renata has had difficulty sleeping. On March 20 she saw her physician, who prescribed medication for anxiety. She has not missed work.

Renata has not filed suit. She wants to know whether an IIED claim is available against Kyle for the reviews, the calls, or both, and whether a defamation claim would be the better route.

Common mistakes

• Leaving out the opinion language and the unattributed accounts because they hurt the client.
• Writing “harassing” or “malicious”; let the dates and numbers speak.
• Forgetting the facts that go to severity (sleep, doctor, prescription) because they feel personal.
• Ending without the question the memo answers.