Michele, a paralegal for a small civil litigation firm, is working with her attorney on a federal civil litigation case. She is helping the attorney with all pretrial matters, including disclosures, discovery, and pretrial motions. No discovery documents or pretrial motions have been filed to date. Michele's firm is representing the plaintiff in the case. The complaint has been filed and the summons issued. The defendant has also filed his answer and affirmative defenses to the suit.

1. Which of the following documents can the defendant file up to a certain amount of days before the trial of this case in order to get the case dropped from the court's docket or to get relief without a trial?

a. Counterclaim

b. Motion to strike

c. Motion for summary judgment

d. Motion to compel

2. Which of the following is not an example of a discovery request that Michele may be asked to draft for attorney review?

a. Deposition summary

b. Request for production of documents

c. Request for admissions

d. Request for physical examination

3. Michele may be asked to prepare initial disclosures as required in accordance with FRCP 26(a)(1). Which of the following is not required to be disclosed in accordance with this rule?

a. Copies of insurance policies that cover the injuries or harms alleged in the suit

b. A computation of damages being claimed by the disclosing party

c. Contact information for any person who is likely to have "discoverable information"

d. Expert witnesses

4. Suppose Michele meets with the firm's client when gathering documents in response to requests for production. During this meeting, the client asks Michele what she thinks of the case and if she thinks the case will succeed at trial. What should Michele tell the client?

a. Michele should tell the client that she is not authorized to give legal advice, but that in her personal opinion the case is going very well.

b. Michele should refer the client's questions to the attorney because she does not have the authority to answer such questions.

c. She should assure the client that the case will be successful in trial. She does not want the client to think anything but good thoughts, regardless of the actual likelihood of success or failure.

d. She should tell the client her honest opinion about the case, specifically, whether she thinks the case would do well in front of a jury or fail.

5. Michele will obtain some electronic evidence as part of the discovery process. Her supervising attorney has reminded her of the two special requirements that she must comply with to ensure that the evidence will be admissible in court. What are these two requirements?

a. Acquire an image copy and preserve the chain of custody.

b. Preserve the chain of custody and back up the metadata.

c. Adhere to the Federal Rule of Evidence 502 and lock up the data.

d. Document the location of the deleted files and preserve the files in a secure location.