Question

Prepare each of the following discovery documents on behalf of Mrs. Hatter in Workbook Exercise 12: (use the document format as illustrated in Appendices C, D, and E in your Legal Document Preparation Manual):1. Request for Answers to Interrogatories (minimum of 15 requests)2. Request for Production of Documents (minimum of 5 requests)3. Request for Admissions (minimum of 10 requests)Mrs. Hatter is a new client. While standing in the check-out line at the local grocery store, Foods Deluxe, the automated belt conveyer belt caught her sleeve as she was placing her groceries on the belt. Flustered by Mrs.Hatter’s scream for help, the clerk was temporarily unable to turn off the belt. By the time the belt was shut off by another customer,Mrs.Hatter’s shoulder was dislocated and she had fainted, cutting her head on the counter as she fell.Mrs.Hatter does not have health insurance or disability insurance. She has not been able to work and has used all of her savings to pay her medical bills. She is unlikely to have a complete recovery and may never again be able to resume her work as an artist.Mrs. Hatter is also very upset about the loss of her one good outfit which was torn in the accident.

Answer 1

Request for Answers to Interrogatories:

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

Mrs. Hatter, Plaintiff, v. Foods Deluxe, Defendant.

CASE NO.:

REQUEST FOR ANSWERS TO INTERROGATORIES

To: Foods Deluxe, Defendant, and its attorney of record:

Pursuant to California Code of Civil Procedure § 2030.010 et seq., Mrs. Hatter, the Plaintiff in the above-captioned action, hereby requests that you answer the following Interrogatories under oath and within thirty (30) days after service of this Request.

DEFINITIONS:

1. “You” and “your” mean Foods Deluxe, Defendant, its agents, employees, representatives, and any other persons acting on its behalf.

2. “Incident” means the occurrence at the Foods Deluxe store on [date of the incident], where the automated belt conveyer belt caught Mrs. Hatter’s sleeve.

INTERROGATORIES:

1. Identify all persons who were present at the Foods Deluxe store on the date of the incident.

2. Identify all employees who were working at the Foods Deluxe store on the date of the incident.

3. Identify all persons who were responsible for the maintenance, inspection, and repair of the automated belt conveyer belt at the Foods Deluxe store on the date of the incident.

4. Describe in detail how the automated belt conveyer belt was designed, installed, and maintained at the Foods Deluxe store.

5. Describe in detail all incidents involving the automated belt conveyer belt at the Foods Deluxe store during the past five (5) years, including any complaints, accidents, or injuries.

6. Provide a complete copy of all documents, photographs, videos, and other evidence related to the incident.

7. Describe in detail all training provided to employees of Foods Deluxe regarding the safe operation of the automated belt conveyer belt.

8. Identify all safety measures in place at the Foods Deluxe store to prevent accidents involving the automated belt conveyer belt.

9. Provide a complete copy of all documents related to any insurance coverage maintained by Foods Deluxe related to the incident.

10. Identify all persons who have knowledge of the incident and provide their name, address, and telephone number.

11. Describe in detail any and all medical treatment provided to Mrs. Hatter as a result of the incident.

12. Provide a complete copy of all medical records, bills, and other documentation related to the medical treatment of Mrs. Hatter as a result of the incident.

13. Describe in detail the impact of the incident on Mrs. Hatter’s ability to work as an artist.

14. Identify all damages claimed by Mrs. Hatter as a result of the incident.

15. Describe in detail all efforts made by Foods Deluxe to investigate the incident.

DATED: [Date]

[Your Signature]

[Your Name]

Attorney for Plaintiff, Mrs. Hatter

Request for Production of Documents:

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

Mrs. Hatter, Plaintiff, v. Foods Deluxe, Defendant.

CASE NO.:

REQUEST FOR PRODUCTION OF DOCUMENTS

To: Foods Deluxe, Defendant, and its attorney of record:

Pursuant to California Code of Civil Procedure § 2031.010 et seq., Mrs. Hatter, the Plaintiff in the above-captioned action, hereby requests that you produce the following documents for inspection, copying, and testing within thirty (30) days after service of this Request.

DEFINITIONS:

1. “You” and “your” mean Foods Deluxe, Defendant, its agents, employees, representatives, and any other persons acting on its behalf.

2. “Incident” means the occurrence at the Foods Deluxe

Step-by-step explanation: