You represent the Defendant, a shoe company.A Plaintiff has filed a Complaint against the shoe company, alleging that they broke their ankle while walking in your client's defective shoes.The Plaintiff claims that they were poorly made and the defects in the design and manufacture caused their injuries.They are requesting approximately $40,000 in damages for hospital care and treatment, as well as $100,000 due to being unable to work now and for at least the next twelve months.

explain which types of discovery procedures you would utilize if you were the Defendant's attorney.