Read the case study and then answer the questions that follow.

Case Study

The attorney you work for, Charles Baker, is representing 60-year-old Darla Griggs, a former administrative assistant for a local stockbroker. One morning, while getting ready for work, Darla was severely and permanently injured when her hair dryer exploded in her hand while she was drying her hair. Darla's right hand, the hand she used for most of her work duties, was so badly burned that it needed to be amputated. Because Darla's recovery and rehabilitation have taken many months, her former boss had to replace her. Your firm is currently suing the manufacturer of the hair dryer, MX, Inc., as well as the retailer from whom Darla purchased the hair dryer, JP's Small Appliances, claiming that the hair dryer's design was defective. You are seeking damages for pain and suffering, lost wages, decreased earning capacity, and future medical expenses.

Most of the discovery has already been completed in the case, but your supervising attorney wants to establish some facts prior to trial. For one thing, he wants to establish that the hair dryer was in the same condition when it left JP's Small Appliances as it was when they received the hair dryer from MX, Inc. He also wants to firm up his understanding of the design of the heating element on the hair dryer to establish that it was the cause of the hair dryer exploding.

MX, Inc. has also served a request for admissions, seeking information about Darla's employment history, claimed damages, and future capacity to work.

If MX, Inc. sought admissions regarding every job Darla has ever held since she was 16, what would your most likely response be?

a. Deny all facts as false

b. Refuse to either admit or deny the request

c. Object on the grounds of attorney-client privilege

d. Object on the grounds that the request is overbroad