formulate a set of requests for production of documents, law homework help

Abel Abrahamson is a client of your firm (Sinclaire and Sinclaire, 464 Main St., Blackacre, Hometown, 37373). The complaint is attached below.

Your supervising attorney has asked you to formulate a set of requests for production of documents for his review, which could be served on the opposing party in our car accident case between Cain and Abel. The facts are:

• He got into an accident with his brother, but his brother turned out into the lane in front of him, causing the accident.
• He believes his brother was intoxicated at the time and was speeding.
• He knows his brother went to the hospital, but is unsure of the extent of his injuries or medical bills. He is sure, however, that his brother is faking some of his injuries–he saw him moving furniture shortly after the accident. This also leads him to believe he could still perform his job.
• He is furious with his brother, and wants to sue him for defamation. His brother has been going around town telling “everyone” that he intentionally ran him over because he thought Cain was going to tell Abel’s wife about an affair Abel was engaged in.
• Abel adamantly denies hitting his brother on purpose, and is furious, as he has never engaged in an affair. Regardless, news of his brother’s statements about him have spread amongst the town, and Abel recently lost an election whereby he was running for the Blackacre School Board. Polling showed he lost the election due to the public’s concern over his moral fitness.