Xerox Inc. is a maker of copy machines. Xerox Inc. was incorporated in the State of Delaware. Most of Xerox’s employees work in California at its manufacturing plant. Betty, a legal secretary at Paul Hastings (a local Los Angeles law firm) suffers severe injuries when one of Xerox’s copy machines explodes on her. Betty files a lawsuit in Delaware against Xerox Inc. for negligence. She is seeking $50,000 in damages. Does a Delaware court have personal jurisdiction over Xerox Inc.?
Using the same facts as question 1, if you were counsel for Xerox Inc., list three documents you would ask Betty to produce (as part of your Request for Production) and state why you would ask for these documents. In other words, what purpose would they serve in defending the lawsuit? Also, name two witnesses you would depose and state why you would depose them.
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