Case Study: Mrs. Hatter Vs. Foods Delivery

Bruce Wayne
Attorney at Law
303 Reims Lane
Gotham, NY 25010
(888)-888-8888
WayneEnterprises.com
[e-mail]

To: Hal Jordan, Esq.
From: Damian Allen, Paralegal
Date: June 24th, 2011
Re: Mrs. Hatter vs. Foods Deluxe
DISCOVERY

The plaintiff, Mrs. Hatter, by and through her counsel, Bruce Wayne, and pursuant to rule 34 requests defendant Foods Deluxe, respond to the following interrogatories, requests for admission, and requests for documents.

I. Interrogatories
1. State the name of the person or persons answering these interrogatories.
2. How many cashiers, managers, and other employees were working at the time of the incident?
3. What was the approximate location of each of the above at the time of the incident?
4. Who was the employee working at the lane in which Mrs. Hatter was injured?

Please provide a list of all customers in the store from half an hour prior to half an hour after the incident.
6. Has this Foods Deluxe ever had complaints about their maintenance of store equipment?
7. How long has the employee at the lane where Mrs. Hatter was injured been working for the company?
8. How many lanes were being used at the time of the incident and how many lanes are there total within the store?
9. How long did it take from Mrs. Hatter being caught in the belt to bystander Dr. Gordon Freeman stopping the belt?
10. How long was Mrs. Hatter unconscious after the blow to her head?
11. Did an employee or a bystander summon the ambulance? If an employee called the ambulance, which one?
12. How many customers use each lane per day, and what percent of the time is the belt running?
13. Was there an employee bagging groceries in addition to the cashier at the lane Mrs. Hatter used?
14. Has any other Foods Deluxe store had a similar incident?
15. What aid was given to Mrs. Hatter by store