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Jim is suing TOYs Inc. claiming injury from one of its products. Which of the following items is not permissible for TOYs Inc. to discover

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Jim is suing TOYs Inc. claiming injury from one of its products. Which of the following items is not permissible for TOYs Inc. to discover as part of the discovery process? 1) Send an interrogatory to Jim requesting him to answer very specific questions in writing as to how he used the product. 2) Discover Jim's private medical records relating to the injury. 3) Discover the work-product of Jim's attorney to better plan for trial. 4) Depose the witnesses Jim plans on calling at trial ahead of time and ask them extensive questions to avoid any surprises at trial

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