The Distressed Grandfather (Dummy bookcase)

Case: The Distressed Grandfather (Dummy bookcase) Help me draft 4 Interrogatories, 3 requests for production, and 3 requests for admission that the defendant (Mrs. Small ) will have to answer. Think through what information would be helpful to know about how the defendant might have acted negligently.

Donald Drake & his 6-year-old grandson, PhilipDrake was about 30 feet behind Philip, when Philip was hit by a car that seemed to be driving out of controlPhilip has killed instantlyThe driver, Mrs. Wilma Small was unhurt.Mr. Drake suffered a great deal of mental pain and shock.He suffered a heart attack -a lengthy hospital stay1 year later, Mr. Drake still has nightmares and now wants to sue Mrs. Small and have her pay for the hospital bills and for his pain and suffering.