One night, Joe, an over-the-road truck driver, was driving on I-70 around 11 p.m.

Hello,

I am representing Joe in the following case and need help drafting discovery items for the pre-trial motion.

I need to submit 10 requests for Admissions to another party and  10 deposition questions for the other party,

One night, Joe, an over-the-road truck driver, was driving on I-70 around 11 p.m.  All of the sudden Joe noticed that there was a car in the middle of the highway with no lights on.  Joe attempted to swerve at the last minute to avoid a collision, but ended up clipping the corner of the passenger’s side of the back bumper of the vehicle causing it to spin.  Along comes John from around a curve; he sees the car and swerves, missing the car entirely.  However, he ran over Greg, a passenger in the vehicle, dragging him 100 feet.  It was clear that Greg was dead.  The coroner determined that it was most probable that Greg was dead before John ran him over.  An expert in traffic accident reconstruction determined that the impact of Joe’s truck with Greg’s vehicle could have launched Greg from the car and into the road.  Greg’s family filed a complaint against Joe and John for wrongful death.  

Thank you