Scenario: On November 2, 2017, Defendant's counsel, with the Court's permission, submitted a letter in which he advised that he had learned, through discovery, that Plaintiff was in the possession of "certain confidential documents"belonging to Defendant. Defendant's counsel requested the Court convene a teleconference to discuss the return of the documents to Defendant.

During the conference calls with the Court, Defendant's counsel explained that Plaintiff had, in response to discovery requests propounded by Defendant, produced copies of documents to Defendant which Defendant believes are wrongfully in Plaintiff's possession. Specifically, Defendant argues that Plaintiff, who previously worked as a paralegal for Defendant, took these documents from Defendant upon her departure from the firm without the firm's authorization. These documents include Document Nos. 6-15, consisting of Plaintiff's time records reflecting work she performed on behalf of firm clients, and Document Nos. 1-5 and 16-55, consisting of e-mails between Plaintiff and her managers and/or the Human Resources department at the firm. As described by the parties, there are three general categories of e-mails: (1) communications regarding Plaintiff's request for a transfer to Defendant's Dallas office, (2) communications regarding Plaintiff's reassignment to Defendants Piarco office, and (3) communications regarding Plaintiff's work assignments.

Defendant requests that the Court order Plaintiff to return all of the above documents to it on the basis that the documents belong to the firm and that Plaintiff is not authorized to possess them.

• Prepare a legal memorandum addressing the issues in this case. Your legal memorandum must take the following format:
  • Question Presented
  • Short Answer
  • Facts
  • Discussion
  • Conclusion