Pamela Peterson, a resident of Columbus, Bartholomew County, Indiana, was driving a Ford Escape when a Audi TT Roadster driven by Darren Davis, a resident of Royal Center, Cass County, Indiana, struck the front end of her vehicle at the intersection of Meridian and 86th streets, Indianapolis, Marion County, Indiana, causing Pamela to suffer a broken leg. She also complained of chest pain. Pamela's car accident was on December 29, 2018. Pamela alleges that the stoplight was green, indicating she could go. She also claims that her vision was not distracted by the sun. Furthermore, Pamela informs her attorney that Darren's vehicle was traveling at a high rate of speed and that Darren did not stop when he should have. She provided her attorney with the following: (1) police report from the Indianapolis Metropolitan Police Department, 50 N. Alabama St., #E211, Indianapolis, IN 46204; (2) hospital bills from St. Vincent Hospital in Noblesville, 9460 E. 146th St., Noblesville, IN 46060; (3) physician bills from Dr. Gregory Gaines, 76th Street, Suite 8, Columbus, IN 47201; (4) insurance statements from her health insurance provider, Anthem Blue Cross Blue Shield, 220 W. Huron, Chicago, IL 60654; and (5) prescription drug information from her pharmacy, CVS, 4495 W. State Road 26, Columbus, IN 47201. So far, her bills total $65,000.00. After Darren Davis received the Appearance, Summons, and Complaint, which detailed all of Pamela's claims, he realized his insurance company did not reach a settlement with Pamela. Darren made an appointment with his attorney, Natalie Neary. The two discussed the case. Information that he told her during their meeting included the following: he does not believe the accident was his fault. He claims that he was driving at the required speed limit, even going a few miles per hour under the limit at times. The stoplight had just turned green, indicating he could drive through the intersection. Therefore, if he had the green light, Pamela's light had to have been red, meaning she was the one who ran the red light, not Darren. Furthermore, Darren told his attorney that his vehicle was struck from behind by a McLaren 720S driven by Kara Klein, a resident of Indianapolis. Darren believes that if Kara's McLaren had not rammed into his vehicle, he would not have collided with Pamela's Ford Escape. Darren has brought Kara into the lawsuit by Impleader. He has since filed his Answer with Affirmative Defenses as well as a Third-Party Complaint. Darren also informed his attorney that two witnesses were at the scene of the accident. The witnesses could back up his side of the case. The witnesses are William Ward, who resides at 56 Westwind Court, Carmel, IN 46082, and Windy Wick, who resides at 100 N. 600 E., Lawrenceburg, IN 47025. Natalie Neary agrees that the witnesses could provide helpful information. In fact, after an initial search was conducted, Ina learned the following: (1) William Ward reported that he saw Pamela Peterson messing with her cell phone, likely trying to send a text. He's not positive, though. (2) William Ward is actually the head of the IT Department for the company where Pamela Peterson is employed. He works at the headquarters office in Indianapolis while she works at a satellite office near her hometown. He told Ina that all employees are required to file accident reports, whether personal or employment-related, with the company in order to gain access to a company vehicle while the employee searches for alternate transportation. It just so happens that Pamela Peterson filed that required paperwork and now drives a company-owned sedan. (3) William Ward monitors the e-mail communication of all employees at his company. He said it is possible that Pamela Peterson has been corresponding with her close friends while at work, mentioning details of the accident. (4) William Ward told Ina that all employees are required to use iPads when traveling because employees are able to produce on-the-spot reports regarding their field work. Those reports are sent directly to supervisors for evaluation. (5) William Ward informed Ina that Pamela Peterson was traveling on the day of her accident for work-related purposes. She was conducting a field study for potential site purchases for redevelopment. (6) Finally, William Ward admitted that he and Pamela are Facebook "friends." He said there was a very interesting post that appeared almost immediately after the accident, but Pamela has since taken it down from the site. #1. What types/methods of discovery would be beneficial to forward for client, Darren