Reference no: EM133338926
Question 1. List the information you would gather and produce on behalf of your client, Diamond Dragon, for the automatic disclosure.
Question 2. List the information you would expect the plaintiffs to gather and produce to you for the automatic disclosure.
Question 3. List examples of the requests for production, or things you would seek through a request for production, from the plaintiffs.
Question 4. List examples of the interrogatories, or the information you would seek through an interrogatory, from the plaintiffs.
Question 5. List examples of the deposition questions you would ask the plaintiffs.
Question 6. Describe whether an independent medical exam would be proper in this case and why, or why not.
CASE HISTORY
Penelope and her husband, Peter, are enjoying their coffee while reading the Sunday paper on their deck overlooking the backyard and in-ground pool at their new home. They have been happily married for seven years, and everything in their life seems to be going well. Penelope, who is thirty-three years old, is very successful in her career. Last year, she was promoted to a high-level managerial position in the accounting firm she works for - she's one of the youngest people ever to attain such a position in the company's history.
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