The summary judgment evidence established that on or about December 26, 2001, TR went to visit her mother, a patient at General Hospital. Instead of parking in the General Hospital parking lot, Terry Randall parked along the curb on Hague Street next to the hospital. She exited the vehicle and walked across the landscaped area to reach the sidewalk. Terry Randall alleges she tripped over a bush sticking about one to two feet out of the ground and sustained injuries to her back and hands. This was the first time Appellant parked along Hague Street at this specific location. The shrub was one to two feet tall, located in a row of green bushes. Appellant testified that she did not see the distressed shrub, but rather that the color of the distressed shrub blended in with the color of the rocks used to landscape that area. Yet, she testified that she could not remember the color of the shrub because of the injuries she received from the fall. Her testimony alone was the only evidence indicating that the shrub was not perceptible. The shrub was approximately one to two feet tall and located in a row of other larger green bushes. There is no direct evidence on the record indicating whether she tripped on a bush or on the rocks, but rather Terry Randall indicated that what else could she think other than she tripped on the bush since she did not see it. Terry Randall indicated that she assumed she was looking down when she first stepped from the street onto the curb, but that she did not see the shrubs between the curb and the sidewalk. However, Terry Randall did see the row of green bushes equally spaced apart, which comprised part of the landscaped scheme. The summary judgment evidence further shows that General Hospital specifically planted the shrubs as part of their landscaping scheme and knew people would park on the street and use the landscaped area to get to the sidewalk. Terry Randall filed a lawsuit against General Hospital wherein she alleged that the injuries and damages she suffered were the proximate cause of General Hospitals' negligence and the negligence of its agents and employees. Specifically, Terry Randall alleged that General Hospital created an unsafe condition, failed to warn her of the dangers, failed to adequately protect pedestrians from the dangerous condition, allowed the unsafe condition to remain without repair, cut the bush to a stump, and failed to remove the stump. General Hospital answered and subsequently filed a no-evidence motion for summary judgment, which alleged that Terry Randall's status at the time and location of the injury was a trespasser and she was required to and failed to introduce any evidence showing that General Hospital willingly, wantonly, or by gross neglect caused her injury. Alternatively, General Hospital argued that if it is determined that Terry Randall was a licensee, the evidence establishes that the alleged hazard which caused Terry Randall's injuries was easily perceptible, relieving General Hospital of any duty to warn of the alleged hazard. .

Read through the hypothetical. Think about Terry Randall's legal status: trespasser, licensee, or invitee at the time the accident occurred. Based on this, think about whether General Hospital has any liability toward Terry Randall in this case. What questions are unanswered by this hypo that you would need to find out in order to determine P's status?

Based on the hypo & its unanswered questions, WHAT IS 7t Interrogatories (ROGS) on the case. Interrogatories are for the defendant's attorney's office. The law office needs to draft a ROGS to the P. Recall that ROGS are designed to uncover evidence. So, your questions should be geared towards determining P's status in this case (trespasser, licensee, invitee).

What are 7 interrogatories that can be asked as the defendents attorney?