Little Jimmy O’Leary, lives in Birmingham, Alabama and works as a law clerk for a federal judge in Mississippi. While Little Jimmy O’Leary hates the humidity of Florida, he owns a vacation home in Marco Island, Florida which he rents out. Over the summer break, Little Jimmy O’Leary decides to visit his father who lives in Marco Island, Florida. While driving on Interstate 75 in Florida, Little Jimmy O’Leary gets into a car accident with Sally Johnson, who owns a vacation home in Florida, but is a resident of New Jersey. As a result of the accident, Little Jimmy O’Leary suffers serious injuries and a totaled car. In addition to severe brain injuries, Little Jimmy O’Leary loses all use of his right arm. Sally Johnson suffers no serious medical injuries, but her Fiat 500 suffers over $5,000 in damages. After recovering from his injuries, Little Jimmy O’Leary returns home to Alabama. Because Little Jimmy O’Leary cannot type with his right hand, he loses his job as a law clerk.
Please identify how Jimmy could obtain the following information via the discovery process. Please refer to the applicable Rule of Civil Procedure that would govern each situation. Also, please list any possible objections to each of Jimmy’s discovery requests.
1. Jimmy’s attorney would like to obtain information about Sally’s car insurance as well as her employment status and assets before filing suit against Sally.
2. Jimmy’s attorney would like Sally to admit in written form that she passed a light and contributed to the accident.
3. Jimmy’s attorney would like Sally to sit for a deposition.
4. Jimmy’s attorney would like a medical professional to physically and mentally examine Sally.