A roofing company, Regal Roofers, repairs people's roofs from leaks and other wear and tear. It presently employs twelve people who do the roofing work, an additional four employees who work in the head office scheduling roofing jobs, and one employee who handles human resources and payroll. Regal Roofers, like all employers, is governed by the following federal statute: Minimum Wages Law Section 1 (a) All employers must pay each full-time employee no fewer than $15 for every hour worked by that employee. i. Exception: employers, who employ fewer than twenty full- time employees, are entitled to pay any employee fewer than $15 per hour so long as that employee agrees to the reduced wage. (b) Any person may sue for any financial losses s/he has suffered due to a violation of this statute. Regal Roofers held an all-employees meeting two years ago. At that meeting, the HR person, Elton Marichal, with the aid of a detailed nine-slide PowerPoint presentation, explained to theemployees that Regal Roofers's policy is to pay each employee an hourly rate in the range of $12/hour to $15/hour. Part of Mr. Marichal's presentation discussed numerous company policies regarding how Regal Roofers complies with the Minimum Wages Law. One of Regal Roofers employees, Martina Spade, who was hired by Regal Roofers approximately two years ago (although she does not know what date), does not recall attending this meeting, nor is she even sure that any such meeting occurred while she was an employee of Regal Roofers. Ms. Spade however was told by a fellow employee, Ron Folds, who recalls that meeting well (he even recalls filling out an attendance sheet at that meeting), that Mr. Marichal mentioned a company policy requiring employee complaints about wages to be submitted in writing. Ms. Spade believes that Regal Roofers has only paid her approximately $13.00 per hour for her work over the last two or so years, and that Regal Roofers has therefore violated the Minimum Wages Law. Ms. Spade decides to sue Regal Roofers for that violation. * * * Ms. Spade's lawsuit is now in the "discovery" phase and you are her attorney. Identify three items of information that would be relevant for you to obtain in this case. (Note: the information might (i) help you prove that Ms. Spade was indeed underpaid or (ii) help you assess whether Regal Roofers will be able to assert a valid defense that it qualifies for the "exception" described in Section 1(a)(i) of the Minimum Wages Law.) For each of the three items of information you identify, please also (i) identify the discovery tool that you would use to try to obtain that item of information and (ii) state why you believe this information is relevant.