Based on the hypo & its unanswered questions, draft Interrogatories (ROGS) on the case. You work for the defendant's attorney's office (General Hospital) and are drafting the ROGS to the Plaintiff, Terry Randall, Recall that ROGS are designed to uncover evidence. So, your Interrogatories should be geared towards determining Plaintiff's status in this case (trespasser, licensee, invitee) and discovering all facts known to Plaintiff, including facts just prior to the incident, how the incident happened and facts just after the incident. Avoid asking Interrogatories which merely require a "yes or no" response. Interrogatories should be drafted in such a way that they require the receiving party to provide a narrative response. In Texas Interrogatories are limited so you want to make the most out of each one