Our office represents Ms. Theresa Sacks with her employment discrimination matteragainst ABC Corporation..Ms. Sacks is 55 years of age and disabled. She is a paraplegic resulting from a caraccident 15 years ago. Ms. Sacks was employed by ABC Corporation for three years as asystem analyst. She received outstanding reviews and merit increases during heremployment at ABC Corporation. Ms. Sacks was terminated by ABC Corporation. The employer did not provide Ms.Sacks with a reason why she was terminated. Ms. Sacks believes she was terminatedbased on her physical disabilities and because ABC Corporation refused to provide herwith reasonable accommodations.

Some of the accommodations Ms. Sacks requestedfrom her employer, both in writing and orally, included wider doorways, modification ofher workstation, and proper office equipment.None of Ms. Sack's requests foraccommodations were acknowledged by ABC Corporation. As a result, our office filed a complaint against ABC Corp. with the Orange CountySuperior Court, Central Justice Center. The complaint demandsdamages for $100,000, plus punitive damages.

The complaint alleges:

1.Ms. Sacks had poor work performance;

2.Ms. Sackswas an "at-will" employee whose employment could be terminated at any time;

3.ABC Corporation met and provided all accommodations under the Americanwith Disabilities Act (ADA).

Createaninformal and formal discovery plan that should be undertaken against the defendant. Please provide reasons for each discovery tool and/or process you set forth in and the plan should be specific and detailed.