Problem
Suppose Polly filed a civil complaint in South Carolina state court naming a company called Dobby's Oyster Shack as the defendant. In Polly's complaint, she alleged that she "suffered a serious illness caused by a Dobby's Oyster Shack employee who negligently served her contaminated oysters." Dobby's Oyster Shack hopes to utilize the tools of discovery to win the case before trial by filing a motion for summary judgment.
1. What are two examples of facts Dobby's Oyster Shack should seek to establish in discovery in preparation for its motion for summary judgment?
2. Explain how Dobby's Oyster Shack should use the specific tools of discovery (interrogatories, subpoenas, depositions, etc.) to establish the facts you identified in question (1).