Joey Tribbiani is an amateur actor. On January 30, 2018, the television company MBC offers Joey a job as a supporting actor on the show Days in Our Life. Joey films Episodes 1 through 5 of Days in Our Life, then unexpectedly learns that his character dies in a car accident in Episode 6. Joey is convinced that MBC fired him because he is Italian. Joey sues MBC in federal court for national origin discrimination under Title VII of the Civil Rights Act. He has retained you as his lawyer.

Question:

What information can be requested to be used for:

1. interrogatories (3)
2. requests for production (3)
3. requests for admission to ask MBC (3)