Based on the following case, draft a set of Request for Production of Documents to send to the defendant that will help establish a clear picture of the maintenance records for the area where the defendant was injured. Ask for documents that might show how and by whom the actual area was designed, inspected, and maintained.

Incident: Friday, October 29, 2022

Location: Mercer University campus

Client, Xamine Locus and three friends drove to Macon, Georgia to visit their friend, Ficer Maxis. Maxis lived on Mercer University campus in Freedman Hall, a University dormitory. Locus is a student at Clark Atlanta University and this was his first visit to the Mercer campus. Locus was studying to become a Math Teacher; held a 3.5 GPA.

Around 10:30 p.m., Locus and his friends arrived in Macon and went to Freedman Hall to drop off their things. There, Locus consumed rum shots. Locus then went to several fraternity parties before taking a taxi to downtown Macon and going to a few bars. Locus drank a couple of beers at the fraternity parties and then had two beers and some pizza in downtown Macon.

After the bars closed at 2:00 a.m., Locus, Maxis and their friends began walking back through the campus to Freedman Hall.

They reached Flagler Hall, and Maxis led the group down the sidewalk behind Flagler Hall, on the north side of the building. Freedman Hall could also have been reached by crossing in front of Flagler Hall, which fronted College Street.

The front of Flagler Hall was well-lit. Street lamps next to the sidewalk behind Flagler Hall were not working and the area behind Flagler Hall was dark.

On the north side of Flagler Hall, the sidewalk was nine feet wide and straight, with a concrete retaining wall on one side and a landscaped area between the sidewalk and the window wells near Flagler Hall. The landscaped area had pine straw and shrubbery but no walkway. The landscaped area had a flexible irrigation pipe, which was stapled in place and covered with mulch.

As he walked behind Flagler Hall, Locus lagged behind and then began jogging to catch up. Locus left the sidewalk and tripped on part of the irrigation system.

Locus fell into a window well eight feet deep.

Thomas Zelk, the maintenance director for Mercer University was the first one on the scene.

When he arrived, Zelk was carrying yellow warning tape and poles to place around the area

Injuries: Locus was knocked unconscious and was unresponsive. He was transported to the hospital, where he stayed for six days. Skull fracture and damage to right frontal lobe. Therapy for 1 year. Memory loss and difficulty focusing. His condition is improving; however, he is considering seeking disability because he is unable to pass exams for his teaching licensing. Locus withdrew from school for medical reasons--still has headaches and severe balance problems.

Locus' blood alcohol level was 0.243, around 4:00 am when tested at the hospital. Locus had "a buzz" and was not really paying attention to where the sidewalk ended. It was also too dark to see where the sidewalk ended and the landscape began.