Prepare each of the following discovery documents on behalf of Mrs. Hatter in Wo

Question

Prepare each of the following discovery documents on behalf of Mrs. Hatter in Workbook Exercise 12: (use the document format as illustrated in Appendices C, D, and E in your Legal Document Preparation Manual):

    2. Request for Production of Documents (minimum of 5 requests)

Mrs. Hatter is a new client. While standing in the check-out line at the local grocery store, Foods Deluxe, the automated belt conveyer belt caught her sleeve as she was placing her groceries on the belt. Flustered by Mrs.Hatter’s scream for help, the clerk was temporarily unable to turn off the belt. By the time the belt was shut off by another customer,Mrs.Hatter’s shoulder was dislocated and she had fainted, cutting her head on the counter as she fell.Mrs.Hatter does not have health insurance or disability insurance. She has not been able to work and has used all of her savings to pay her medical bills. She is unlikely to have a complete recovery and may never again be able to resume her work as an artist.Mrs. Hatter is also very upset about the loss of her one good outfit which was torn in the accident.

Explanation / Answer

Mrs Hatter who had gone to the grocery shop first time for doing purchasing an untoward incident happened where she fell in the escalator due to which she has had the severe injuries in the shoulder and the face which resulted into dislocation of the bone in the hand/fracture. She has to file a legal case where she shall be required to file a case showing the neglegance by the store staff.

To,

The Legal Manager/officer.

Dear Sir,

With due respect i Mrs Hatter Who had gone to do shopping from your retail store met with severe accident in your premises and had been wounded severly in the escalator. At the time of the incident none of your staff was availaible neither the store manager/admin staff. This resulted into a severe tragedy where i fell into the escalator resulting into injuries in my head and the hand.I have invested lot of savings and money into my treatment now also am not perfectally fine.

You are requested to give your stand on this why legal action shall be not taken against you as this is thecase where sheer negligence was followed which resulted in losses. Request you to suitaibly compensate me or else i am bound to take a several and legal action against your staff and the retail store.

Thanks you in Anticipation

Yours Faithfully.

Thanks and Regards

Mrs Hatter

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