John Smith calls into your office to determine if he has a legal claim against ABC Roofing. Mr. Smith advises that he hired ABC Roofing to repair damage to his roof. He further explains th

Good morning,
Case:
John Smith calls into your office to determine if he has a legal claim against ABC Roofing. Mr. Smith advises that he hired ABC Roofing to repair damage to his roof. He further explains that his daughter’s knee was seriously injured from falling off a ladder left on Mr. Smith’s premises by ABC Roofing. Mr. Smith advises that he told ABC Roofing to pick up any equipment and debris before leaving each night to avoid any accidental injuries. You have been asked to determine any legal claims that Mr. Smith may have against ABC Roofing or any other party to the incident
Can you please use the case above to develop 15 questions I would ask my client and the reasoning for the questions?
Are there any legal claims the client may have, and what are the elements of each cause of action?
What information would I need or may need to prove the elements of each cause of action successfully?
What, if any, physical evidence would I ask Mr. Smith to bring before the meeting, and what would be the relevance and reasoning for each piece of evidence to the case?
Thanks