As we learned in Week Two, Hilda, your client, was in a motor vehicle accident with Zeus. Your law firm (Hamer, Huerta, Jordan, and Yousafzai) has filed a complaint against Zeus on behalf of Hilda. A partner in the firm has now asked you to proceed with preparing discovery. Pprepare a memo to the partner addressing the following:

1. Examine the discovery rules in your home state (CALIFORNIA). Cite those rules and explain each.
2. Offer a detailed summary of your discovery plan.
3. What is a deposition? Who would you depose and how would you arrange the deposition? Discuss three issues that you would like to ask the person you depose. What if the other party objects to one of your questions?
4. Would you need to subpoena any information? Explain.
5. What if the other party fails to respond to your requests? What action can you take? Cite the Rules of Civil Procedure in your home state.