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You are on your way to the conference room at your law firm to meet with your supervising attorney to review the facts in a

You are on your way to the conference room at your law firm to meet with your supervising attorney to review the facts in a case the firm will be handling. The client is a young man named Spencer Flannigan. Mr. Flannigan made a special trip from Rhode Island to Vermont to take advantage of the new state-of-the-art computerized diagnostic lab at the Lassiter Central Clinic of Vermont (LCCV). Unfortunately, Mr. Flannigan was injured during what should have been a routine diagnostic radiological procedure at the new lab. As a part of this diagnostic procedure, Dr. Bethany Randall, a radiologist and one of the defendants in the case, was scheduled to inject Mr. Flannigan with a contrast medium. A contrast medium is a dye that helps the radiologist visualize the patient's internal organs. The facts indicate that Mr. Flannigan had an allergic reaction to the contrast medium and almost expired in the Radiology Department at LCCV. At this point in the discovery process, a deposition has been planned for today. The person answering questions during the deposition will be Jonathan Harbinger, a certified radiologic technologist at LCCV. Harbinger is not a party to the action. Instead, he is a witness who was working in the LCCV Radiology Department at the time of the incident in question. Harbinger is expected to testify about certain irregularities in Dr. Randall's procedures on the day of Mr. Flannigan's test.

Assume that you are the paralegal who has been assigned with creating the deposition questions in preparation for the oral deposition of Jonathan Harbinger. What questions would you ask Harbinger? What areas need to be covered? Why?

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