While she was on vacation in Colorado, Laurie (a resident and citizen of Illinois) was driving back to her hotel in her new car, which was insured by Allstate. As Laurie approached an intersection, put on her right turn signal and started to brake, Laurie received a text message from her friend and Laurie looked down to type a response. At the same time Laurie starting looking down at her phone, David (a resident and citizen of Illinois who was also vacationing in Colorado)was riding a bike in a bike lane closely behind Laurie. David was in a hurry and was focused on making it through the intersection before the light turned red. Right at the time Laurie started to turn right at the intersection, David had caught up to her and, without realizing that Laurie was turning, crashed into the side of her car as he was trying to drive straight through the intersection. David flipped over Laurie’s car and suffered various injuries, including a severely broken leg and a concussion. Although Laurie was not injured, the collision with David caused $10,000 in damage to her new car. At the time of impact, Laurie had her turn signal on, was driving an appropriate speed, and had the right of way to turn right because she was in front of David; however, she was looking at her phone to send a text at the time of the accident and therefore was not fully aware of her surroundings at the time of impact. At the time of impact, David did not notice Laurie’s turn signal or brake lights and did not realize she was turning before crashing into her new car. While David was being transported to the hospital, the ambulance had to make a sudden stop to avoid an accident and David fell off the gurney. As a result of his fall, David also broke his arm. Although David eventually fully recovers, he incurs medical expenses of $50,000 to treat his broken leg and concussion, $5,000 to treat his broken arm and is out of work for three months because he is unable to drive. David files a lawsuit against Allstate and Laurie seeking $80,000 to cover his medical expenses, lost wages and pain and suffering. Please draft a memorandum to a claims manager at Allstate examining Laurie’s potential liability for David’s injuries(Allstate, as Laurie’s insurer, will be liable for this amount on her behalf). Please focus your memorandum on answering the following questions: Which courts would have subject matter jurisdiction over David’s lawsuit (i.e., state and/or federal courts)? Which courts would have personal jurisdiction over Laurie? Assuming for purposes of this question only that the lawsuit could be, and is, filed in Illinois state court, what substantive and procedural law will the court apply? Will David be able to recover damages for the tort of negligence? If David is able to prove all the elements of negligence, would Laurie have any defenses to the negligence claim? What injuries would Laurie be liable for if David establishes Laurie’s liability for the tort of negligence?