Your client, Bradley Harper, a university football coach, has been accused of making his players shoot steroids. A student newspaper reporter, Sheila O'Fay, hears a rumor that Harper has been giving the players steroids. O'Fay happens to sit next to two football players in one of her classes and asks the players whether they know anything about it. They say that they don't take steroids but that they have heard the rumor and think there might be some truth to it. O'Fay does no other investigating nor does she attempt to contact your client before publishing a story in the university-funded newspaper, in which she affirmatively states that Harper makes his players shoot steroids. In the story, she cites the two football players as sources but does not mention their names.

The rumor turns out to be false. Harper has never given any players steroids, and all the players, as well as the other coaching staff, testify to it. Harper now comes to your firm, Scott and Free, P. A., hoping to file a defamation suit against the student. Remember, Scott and Free, P.A. are located in Ohio thus you will use the law of Ohio

Question:

The defendant has scheduled Harper's deposition to be taken in attorney Donald Smith's office in thirty days. Your supervising attorney, Gerard Haddad, has sent you a memorandum directing you to notify Harper about the deposition and to prepare him for it. Identify the questions that Harper should be prepared to answer.