Which оf the fоllоwing is а wаy physicаl therapists can help reduce stigma surrounding mental health conditions?
TO: NEW ASSOCIATES FROM: SENIOR PARTNER RE: PETERSON V. DON’S SCOOTERS Our lоng time client, Dоn’s Scоoters, hаs been served with а lаwsuit filed by Patrick Peterson (P). Don’s Scooters (D) is a business incorporated and operating in the state of Texas. Don’s is a manufacturer scooters that are sold only from its factory store in Texas. However, Don’s sells to a distributor. The distributor has freedom to sell wherever; Don’s is not involved in advertising, selling or distributing the scooters, nor does Don’s have a say where the scooters are sold by the distributor. Don’s only advertises in Texas. The distributor has sold the scooters to Citrus, a company that places scooters in various cities to be rented via the Citrus App. In order to do this, Citrus modifies the scooters to add technology that allows the App to activate and deactivate the scooter via credit card. Peterson rented one of these scooters in Las Vegas, Nevada which he was visiting from California. While he was using it, the scooter wheels suddenly jammed probably due to an App malfunction, causing the scooter to stop suddenly. Peterson was thrown over the front of the scooter, crashing headfirst into the side of the world’s largest slot machine. Peterson broke his back but fortunately it has not caused paralysis. Peterson has sued Don’s Scooters, Citrus and the distributor. The lawsuit was filed in a state court in the state of Nevada. Don’s Scooters was served at their corporate office in Texas. Don’s did not specifically know that Citrus was renting the scooters in Nevada but generally knew that the scooters could be rented anywhere Citrus operated. Don’s does not have any control about where Citrus uses the scooters. Coincidentally, however, is the fact that Don’s also makes and sells scooter t-shirts (for example, “Scootin’ Makes Me Happy”). Besides selling at its factory store in Texas, it sells the t-shirts directly to retail stores throughout the United States including retail stores located in Nevada. Don’s has come to us asking if it is subject to personal jurisdiction in Nevada. Please prepare a memo to me analyzing whether Don’s is subject to jurisdiction in Nevada. Assume that Nevada has a long-arm statute consistent with the United States Constitution. Fully discuss all potential bases for personal jurisdiction and explain your answer. Do not discuss any issues of venue or substantive law.