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Assume that you are a paralegal working for Attorney Juliana Dahl Johnson who represents Renee in the above hypothetical. You have been asked to suggest

Assume that you are a paralegal working for Attorney Juliana Dahl Johnson who represents Renee in the above hypothetical. You have been asked to suggest an appropriate discovery plan to guide the information-gathering effort in this case. The plan you propose should identify the kinds of information needed, the techniques to be utilized (both formal and informal), the sequencing of efforts, and assignment of tasks, After she reviews and approves the plan, attorney will eventually estimate the projected cost and discuss the plan with Renee. The fact pattern indicates Renee is filing for divorce on the grounds of adultery. Assume that in the jurisdiction where you reside and or are employed, (North Carolina) when making property division decisions, the court considers both conduct during the marriage and financial and nonfinancial contribution to the marital enterprise. Your plan should include at a minimum five examples of informal discovery. It should also include use of at least three methods of formal discovery with examples of the kinds of information to be sought using each method. You should consider weaving electronic discovery into various aspects of your plan.

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