You are a paralegal for a defense firm that defends personal injury claims involving car accidents. Your client is being sued for a car accident in which the client rear ended the Plaintiff who was stopped at a red light. Plaintiff alleges permanent and serious neck and back injuries and wants compensation for the injuries and lost wages.

Your attorney has requested you to a memo outlining what discovery you need to do to defend this claim. create a memo to your attorney thoroughly responding to the following questions:

1. What discovery devices do you recommend be used?

Explainwhat information you are hoping to get with the use of each discovery device, or what you hope to prove or use as evidence with the same, regarding the devices you identified in your answer to #1 above.