The trade secret misappropriation lawsuit brought by your client, Plotkin, Inc., against Dristol Kastol and Educom, Inc. has now moved into discovery. The parties have exchanged their Rule 26(a)(1) initial disclosures. Educom's initial disclosures are provided here:

You have been tasked with preparing a first draft of a set of discovery requests. The supervising partner would like you to draft some interrogatories under Rule 33 and requests for production under Rule 34 in order to obtain more information to support Plotkin's trade secrets claim. The partner would also like you to research the mechanism under the rules for deposing a person at Educom that is familiar with Educom's revenue relating to Carbonium. You can use the samples provided in the book along with any others that you can easily find.

Assignment:

• Using the facts & law from written exercise 1 together with the provided initial disclosures, draft 2 interrogatories to Educom and 3 requests for production of documents to Educom. Make sure to consider Rule 26(b)(1) in drafting your requests. You do not need to create a fancy heading or write definitions or special instructions. You only need to write the 2 interrogatories and 3 requests for production themselves.
• Review the rules that I assigned relating to discovery (Rules 26, 30, 31, 33-36, 37 and 45) and write a short description of how to depose a person at Educom that is familiar with Educom's revenue relating to Carbonium. Your description should be no more than 4 sentences. Hint: you do not need to have prior knowledge of this person's name.