Case : The Distressed Grandfather (Dummy book case)

Help me draft 4 Interrogatories, 3 requests for production, and 3 requests for admission that the defendant (Mrs. Small ) will have to answer. Think through what information would be helpful to know about how the defendant might have acted negligently.

Donald Drake & his 6-year-old grandson, PhilipDrake was about 30 feet behind Philip, when Philip was hit by a car that seemed to be driving out of controlPhilip was killed instantlyThe driver, Mrs. Wilma Small, was unhurt.Mr. Drake suffered a great deal of mental pain and shock.He suffered a heart attack -a lengthy hospital stay1 year later, Mr. Drake still has nightmares and now wants to sue Mrs. Small and have her pay for the hospital bills and for his pain and suffering.