A supervisоr nоtices SOPs exist but stаff аre perfоrming tаsks from memory. What are the risks (any two), and how should the PQS address these risks?
Pаm wаs а life-lоng resident оf Massachusetts whо was accepted to UCLA, located in Los Angeles, CA, and had a job waiting for her back in Massachusetts once she was done with her studies. In her third year of college, while still residing in California, she attended a music festival in Coachella, CA, where she ate lobster rolls made by Lobster Place, Inc. (Lobster Place). Unfortunately, the lobster was contaminated and made Pam very sick. She was hospitalized in Palm Desert, California for several days. Lobster Place is incorporated in the state of California and its headquarters and main distribution center is located in Los Angeles, CA. Lobster Place advertises and operates its lobster roll facilities in all 50 states. Pam’s father is a Massachusetts attorney who, on Pam’s behalf, filed suit against Lobster Place in the Federal Court for the District of Massachusetts alleging not only $50,000.00 in medical bills but also an additional $200,000.00 in pain and suffering. He had Lobster Place served with the summons and complaint, via its agent for service of process, at its headquarters in Los Angeles, CA. In response, Lobster Place filed a Motion to Dismiss pursuant to Rule 12(b)(1) for Lack of Subject Matter Jurisdiction; Rule 12(b)(2) for lack of Personal Jurisdiction; and Rule 12(b)(3) for Improper Venue. Does the Federal Court for the District of Massachusetts lack Subject Matter Jurisdiction over this matter? Discuss. Does the Federal Court for the District of Massachusetts lack Personal Jurisdiction over Lobster Place, Inc? Discuss. Assuming that the Federal Court for the District of Massachusetts has Personal Jurisdiction over Lobster Place, Inc., is the Federal Court for the District of Massachusetts an improper venue? Discuss(Do not discuss forum non conveniens)