Fanny Franks, a litigation paralegal, is working for a large law firm defending the Oxxon oil refinery in a big toxic tort case.Fanny is in charge of the document productions and response to discovery.George Gunderson, one of the lawyers on the case, tells her not to answer about two-thirds of the interrogatories that have been propounded and to draft objections to the rest based on irrelevance and privilege.Fanny reviews the interrogatories and sees only two that might be objectionable.She believes that George wants to make these objections to wear down the opposition.Opposing counsel is a small law firm that is handling only this one case at the moment because the case is so big.Its existence depends on winning, and it currently has no other source of revenue.

What should Fanny do?

A few weeks later, Fanny is preparing the documents that will go to opposing counsel in response to document production.She notices that a key internal memorandum from an employee to management about the toxicity levels at the site in question is missing from the documents she has been working with.

What should Fanny do?