Peter and Penelope decide to do some yard work. Peter goes to the storage shed to get the skimmer, vacuum, and water supplies. Penelope goes to the shed to get her pruning sheers and the new power blower-mulcher combination tool, the "Mulch Monster." The Mulch Monster is manufactured by Diamond Dragon Ltd., a German corporation that distributes its products through Tools R Us a national retail chain that just opened a store at the local mall. As Peter skims the pool, Penelope blows the leaves she has just trimmed into a tidy pile. She then removes the blower attachment to convert the tool into a mulcher so that she can mulch the leaves for Peter's organic garden. Peter suddenly hears Penelope scream in pain, yelling for help. He turns and sees her holding her bloody hand. Somehow, three of the fingers on her right hand came into contact with the blades in the mulcher. Peter wraps Penelope's hand in kitchen towels and rushes her to the emergency department at a local hospital. On the way, Penelope tells Peter that she isn't sure she put the attachment on the tool correctly, and repeatedly asks him, "How could I be so stupid?" before going into shock. Peter tries to console and calm her as they pull into the hospital. After examining and stabilizing Penelope, the local hospital transfers her to a major teaching hospital in a nearby city. Despite the surgeons' efforts over the next few days, Penelope's fingers can't be saved. Two of them are amputated at the first knuckle and one is amputated at the second knuckle. The only good news from the doctors is that Penelope is pregnant. Six weeks after the injury, Peter's sister, a corporate lawyer, advises Peter and Penelope to speak to a personal injury attorney and to investigate whether the tool was designed and/or manufactured with defects. Peter and Penelope are reluctant to do so. Penelope is somewhat depressed about her appearance, and is just now returning to work after physical therapy. She has had a difficult first trimester: she suffers from anxiety, and has lost weight and has difficulty sleeping. Several months later, To celebrate, Peter and Penelope have a small dinner party for the friends and family who have been supporting them emotionally through the recent turmoil in their lives. Peter's sister attends, and asks them if they have consulted an attorney. When she learns that they haven't, she again urges them to do so. While cleaning up after the party, Peter and Penelope begin discussing that option and agree that they should pursue it. The next week, they consult an attorney with experience in products liability claims. The attorney is familiar with the Mulch Monster and begins investigating a claim on behalf of Penelope, Peter and Parker. Because the statute of limitations is about to run out, the attorney hastily files suit in court, naming Tools R Us and Diamond Dragon Ltd. You have just started working as a paralegal in the law firm that represents Diamond Dragon.

1. List the information you would gather and produce on behalf of your client, Diamond Dragon, for the automatic disclosure.
2. List the information you would expect the plaintiffs to gather and produce to you for the automatic disclosure.
3. List examples of the requests for production, or things you would seek through a request for production, from the plaintiffs.
4. List examples of the interrogatories, or the information you would seek through an interrogatory, from the plaintiffs.
5. List examples of the deposition questions you would ask the plaintiffs.
6. Describe whether an independent medical exam would be proper in this case and why, or why not.