You are a paralegal working for a law firm. Amber from the following scenario has sought the counsel of one of your attorneys. The attorney was busy and asked you to letter to send to Amber outlining what the pre-trial procedure will be in this case. Your letter must include the pleadings that would likely be filed Amber steps the discovery process and what each side side will look for in this discovery. You must include the tools of Discovery and what is likely to occur in this case so Amber is appraised of her situation fully.

Scenario:

Mary Mary had been having headaches for a month when she went to Morgan's Fast Fix Health Center. On December 1st Mary went to the Health Center and saw Dr quack. Dr quack to the health history on Mary and tartar $80. He told her the headaches were a result of untreated allergies. He told her to take Tylenol and Zyrtec. If the headaches work better in 6 weeks he said she said she could see her up another doctor. On December 5th Mary collapsed at work. She was taken to the hospital by ambulance and is in a coma. The doctor determined she had a brain aneurysm which could have been controlled if it had been diagnosed on December 1st. This particular type of blood clot would have dissolved if she had taken the medicine dissolve X. The hospital doctor is astonished at the treatment Mary received from Dr quack. The hospital doctor called dr. Quack to ask for the records. Dr quack was very abrasive and told the hospital doctor "All of my patients receive the very best care and I resent the implication that they don't. If you tell anyone she didn't receive the best care I will talk to my lawyer." Mary is still in a coma but her adult daughter Amber has power of attorney to do what needs to be done. It is unknown whether Mary will ever recover and what her condition will be if she recovers Mary had health insurance with which will pay for her Hospital stay assuming she doesn't hit the lifetime limit.