For this assignment assume that your firm, Stahl & Beetum, PC, 13 Legal Ave., Wigmore, IL 00001, has been retained to represent the Defendant City of Lyons in the Dorite case. You just finished reading the Complaint, and that is all you know about the case. Your supervising attorney, B. G. Brothers asks you to draft interrogatories, and a notice to produce to be served on the plaintiff as well as a notice of deposition for the Plaintiff. She tells you that she wants information about witnesses, the facts, the plaintiff’s injuries, her past medical history and her medical bills, amongst other items.
She reminds you that the Plaintiff has to provide facts to establish each allegation of her Complaint. She further reminds you that the purpose of discovery is to find out as much information as possible about the plaintiff’s case and her background. Remember, she says, that Ms. Dorite has a good friend who may have given a written statement. She then tells you that the format of both documents should follow the court rules and hands you a copy of the applicable Wigmore Court Rules. She states that she does not want a definition section in the Notice to Produce as she has a definition section that she will add to your Notice. She wants the three discovery documents by Sunday evening at 1159pm. She adds that since the firm is new it does not have forms so you have to find a form to use on the internet or lexisnexis.
- Find and cite your state’s rules on interrogatories, notice to produce documents, and depositions. Use these rules when drafting the discovery documents listed below.
- Draft Defendant’s First Set of Interrogatories to Plaintiff that your firm as attorney’s for the City will propound on the Plaintiff’s attorney Rich N. Moore. The document should contain ten interrogatories seeking information from Ms. Dorite about her case.
- Draft Defendant’s First Notice to Produce Documents to Plaintiff that your firm as attorney for the City will serve on the Plaintiff’s attorney, Rich N. Moore. The Notice should contain five categories of documents for the Plaintiff to produce.
- Draft a Notice of Deposition for the Plaintiff’s deposition selecting a date and time that suits your schedule.