Analyze the following hypothetical fact pattern. Then use course, library or online academic quality resources to help you explain which types of discovery procedures you would utilize if you were the Defendant's attorney. Please make sure you also consider possible witnesses.
You represent the Defendant, a shoe company. A Plaintiff has filed a Complaint against the shoe company, alleging that it caused her ankle to break while she walked in your client's defective shoes. The Plaintiff claims that the shoes were poorly made and the defects in the design and manufacture caused her injuries. She is requesting approximately $40,000 in damages for hospital care and treatment, as well as $100,000 due to being unable to work now and for at least the next twelve months.