Candice Lampe owns a ski rental company in the mountains of Colorado. She has been in business for 12 years and takes great pride in providing skiers with safe and reliable equipment. She regularly tests the equipment and replaces skis, binding, and poles as needed.

Bruce Merriman is on his first ski trip and is a bit nervous. Candice outfits Bruce with all of the necessary equipment, taking care to explain its proper and safe use. Candice advises Bruce to take ski lessons before hitting the slopes and gives him the names of a few ski instructors in the area.

After leaving Candice's rental shop, Bruce meets up with his friends who are much more experienced skiers, and they dismiss the idea of getting a ski instructor. They tell Bruce they'll teach him everything he needs to know.

Bruce heads to the slopes, and on his first downhill he wipes out and breaks a leg, along with one of Candice's skis and a pole. At the hospital, Bruce's friends convince Bruce that Candice must have rented him faulty equipment, or why else would it have broken so easily? Bruce's friend, Cal, is an attorney, and he tells Bruce he should sue Candice. Cal tells Bruce he'll even line up an expert who will testify the equipment was faulty.

Candice is devastated when she is sued. She asks the law firm where you work to help her defend herself and her good name. The attorney you work for asks you to start working on discovery.

Which of the following does Bruce need to provide to you without a formal discovery request?

a. Identity of potential witnesses

b. Evidence of damages

c. Documentary evidence

d. All of these choices.