Exam 9: Document Production and Control, Medical Exams, Admissions, and Compelling Discovery

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Help in locating specific documents for production can come from

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Assume that you are a paralegal for Mercury Parcel and have received the following requests for admissions from Forrester's attorney: a. Defendant Hart was an employee of Mercury Parcel Service, Inc. on Tuesday, February 23, _. b. Plaintiff Forrester's conduct did not negligently contribute to the accident on February 26, _. c. No follow-up maintenance was performed on vehicle 23 regarding locking wheels between the time of the filing of the complaint and the accident on February 26, as confirmed by the unchecked follow-up item on form ICC-2015, No. 37. d. Defendant Hart's supervisor, John Roosevelt, was advised to tell Defendant Hart not to fill out a company accident report after the accident. Reflect on each item and draft what you think would be the proper response to each item. Your responses should vary. Use the format that follows: REQUEST NO. 1: Defendant Hart . . . RESPONSE: (Admit, Deny, Other)

(Essay)
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A request for admission seeks to

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Describe the process for handling privileged documents in screening and preparing the documents for production.

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What is the Freedom of Information Act? Why is it potentially useful to you as a litigation paralegal?

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What are three steps to prevent spoliation of evidence and its sanctions?

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In Case V from Chapter 1, assume that Carlos Montez has refused Ms. Rakowski's request to produce reports of previous incidents of harassment. He has objected on the grounds that this is irrelevant. Briefly stating that this may lead to relevant evidence, draft a motion to compel the answer.

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What must be demonstrated to be granted a FOIA request, and what procedure must be followed to have such a request approved?

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What advantages does the standardized decimal document numbering system provide over other systems?

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The ABA's Legal Technology Advisory Council is set up to help firms handle large volumes of documents.

(True/False)
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When copying documents for production, you should

(Multiple Choice)
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If documents are properly identified and indexed, locating them requires

(Multiple Choice)
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What security precautions need to be taken in computer document control?

(Essay)
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List the four primary steps for the production of documents and things in response to a request to produce.

(Essay)
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Draft the Request for Physical and Mental Examination from Mercury Parcel Service, Inc. to Mrs. Forrester. Be sure you comply with your state rules.

(Essay)
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Match each item with the following correct statement. -Mr. Hart was intoxicated at the time of the accident.

(Multiple Choice)
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What steps should be followed and indexes kept at the examination stage? What steps are important when returning documents that have been produced to the original custodian?

(Essay)
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At the examination of the documents, you do not need to

(Multiple Choice)
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Assume that you have been assigned to a very complex litigation case involving a series of construction contracts for a downtown mall, office, and residential center. You have never worked in this highly technical field. Explain in general terms how you would prepare a Mini-Guide to Construction Records to assist you in interpreting such records over the next three years of litigation.

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According to the cost hierarchy, the most expensive data to produce is

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