(The Distressed Grandfather)

*Donald Drake & his 6 year old grandson, Philip

*Drake was about 300 feet behind Philip. when Philip got her by a car (Mrs. Wilma Small ) was driving out of control.

*Philip was killed instantly.

*The Driver , Mrs. Wilma small was not hurt

*Mr., Drake suffered a great deal of mental pain and shock

He suffered a heart attack- lengthy stay in hospital

*1 yr later, Mr drake still as nightmares and wants to sue Mrs. small and have to pay for hospital bills and for his pain and sufferings

If you were doing the discovery plan for Mr. Drake, what methods of discovery would you prefer? Why?Would your answer change if you were representing Mrs. Small?Why or why not?