Module 03 Content My supervising attorney has asked you to formulate a set of interrogatory questions and requests for production of documents for his review, which could be served on the opposing party in a car accident case between Cain and Abel. Abel, our client, was sued by his brother. He also will need a subpoena for a third-party witness, Ms. Bunny Rabbit. Templates for each document are provided for you. The facts of the case are as follows:

Abel Abrahamson is a client of your firm (Sinclaire and Sinclaire, 464 Main St., Blackacre, Hometown, 37373). He recently received a Summons and Complaint from the Blackacre Circuit Court in your home state, informing him that his brother, Cain, is suing him. The complaint is attachedbelow.

1. Activity Complaint.pdf

Your supervising attorney, Jake Smalls, has already served an Answer and Counterclaim on behalf of Abel, based off of a conversation with Abel, who has given him the following information:

• He got into an accident with his brother, but his brother turned out into the lane in front of him, causing the accident.
• He believes his brother was intoxicated at the time and was speeding.
• He knows his brother went to the hospital, but is unsure of the extent of his injuries or medical bills. He is sure, however, that his brother is faking some of his injurieshe saw him moving furniture shortly after the accident. This also leads him to believe he could still perform his job.
• He is furious with his brother, and wants to sue him for defamation. His brother has been going around town telling "everyone" that he intentionally ran him over because he thought Cain was going to tell Abel's wife about an affair Abel was engaged in.
• Abel adamantly denies hitting his brother on purpose, and is furious, as he has never engaged in an affair. Regardless, news of his brother's statements about him have spread amongst the town, and Abel recently lost an election whereby he was running for the Blackacre School Board. Polling showed he lost the election due to the public's concern over his moral fitness.

Your supervising attorney has advised you that a claim for defamation requires allegations of a false statement, published (or spread to other people) causing damages.

Mr. Smalls would like 10 interrogatory questions included in the interrogatories to be served on Cain. He has provided a template the firm uses for interrogatories for formatting purposes.

1. Week-3-Interrogatories-Template.docx

You need to draft the appropriate questions, paying particular attention to the facts of the case, but feel free to look at more sample questions from the internet or on court websites, such as the Hawai'i State Judiciary's website, located here: https://www.courts.state.hi.us/selfhelp/courts/forms/oahu/circuit_court_forms.

Mr. Smalls would like 10 requests for production of various documents which may be helpful or shed light on this case, which are to be served on Cain. He has provided a template the firm uses for requests for production for formatting purposes. You need to draft the appropriate requests, paying particular attention to the facts of the case.

1. template

Your supervising attorney also would like to depose a witness to the accident, Ms. Bunny Rabbit. Ms. Rabbit lives at 123 Looney Tunes Dr., in Whiteacre. Using the template provided by your firm, prep a subpoena for Ms. Rabbit.

1. Week-3-Subponea-Template.doc

Your supervising attorney has asked you to schedule the deposition with the opposing attorney, so the dates and times are up to you.

Format:

• Your assignment should be formatted according to the templates provided.