Question: Sam Echols was injured when he was hit while crossing the road by a car driven by Becky Samuels. Echols's lawyer suspects that Ms .

Sam Echols was injured when he was hit while crossing the road by a car driven by Becky Samuels. Echols's lawyer suspects that Ms

.

Samuels was not wearing her contact lenses at the time of the accident as she is required to do by law. After filing a suit, how can Echols's lawyer find out whether Ms

.

Samuels was wearing her contact lenses?

.

By subpoenaing Ms

.

Samuels

.

By a request to produce

.

By a deposition of Ms

.

Samuels

.

The information is privileged and non

-

discoverable

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