Catherine owns a famous restaurant called Yummy Foods. During a busy night at the restaurant, a spark went off in the kitchen and caused a fire. The restaurant had to immediately shut down. Catherine does not know the cause of the fire. Yummy Foods' insurance company will cover only damage that is accidentalnot intentional. After the event, Catherine had to rebuild the restaurant's kitchen and she had to keep the restaurant closed for four months. CAtherine photographed the damage and the repair process. Yummy Foods' insurance company refused to pay for any of the repair costs or business interruption expenses. Yummy Food sued its insurance company for bad faith in federal court. Yummy Food hires you as its attorney.

Question:

What can be considered as discovery tasks (5-10) for a a discovery plan for Yummy Foods?

Notes:

1. Request is for production of documents to the insurance company.

2. Take the deposition of the insurance company's person most knowledgeable.

3. Assume that all of Famous Kitchen's employees are friendly witnesses.