Using the fact pattern from the complaint you drafted in Week 5, prepare a deposition outline for the deposition of Rachel. Include some background questions as well as questions regarding the alleged breach and damages. Identify documents about which you will ask Rachel.
Recall Fact Pattern from Complaint:
Just four months ago Rachel and Ralph, a high-end designer store, entered into a contract with Ralph Lauren. Pursuant to the contract, Rachel and Ralph paid $100,000 for a variety of Ralph Lauren clothing for its store. The clothing was supposed to arrive two months ago, but Ralph Lauren’s factory went on strike, and Ralph Lauren sent Rachel and Ralph a notice that it would be unable to fulfill the order. Rachel and Ralph wants to sue Ralph Lauren in federal court for breach of contract, and the company hired you to represent it.
Discussion Instructions
Draft a deposition outline with 10 questions.
Identify the key documents you intend to ask questions about in the deposition outline (for example, the relevant contract, the relevant invoice, etc.).
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