Monica Gellar owns a famous restaurant called Famous Kitchen.

Fact Pattern

Monica Gellar owns a famous restaurant called Famous Kitchen. During a busy night at the restaurant, a spark went off in the kitchen and caused a fire. The restaurant had to immediately shut down. Monica does not know the cause of the fire. Famous Kitchen’s insurance company will cover only damage that is accidental—not intentional. After the event, Monica had to rebuild the restaurant’s kitchen and she had to keep the restaurant closed for four months. Monica photographed the damage and the repair process. Famous Kitchen’s insurance company refused to pay for any of the repair costs or business interruption expenses. Famous Kitchen sued its insurance company for bad faith in federal court. Famous Kitchen hires you as its attorney.

Discussion Instructions

discovery plan for Famous Kitchen. Outline your discovery plan. For example, follows:

Draft request for production of documents to the insurance company.

Take the deposition of the insurance company’s person most knowledgeable.

Outline 5-10 discovery tasks, but no more than 10 discovery tasks.

Assume that all of Famous Kitchen’s employees are friendly witnesses.