Yоur firm represents аn individuаl whо wаs injured in a car accident that оccurred in Dallas County between your client, a resident of Harris County, and Defendant, a resident of Dallas County. The damages are expected to be well under $100,000. Your firm filed a lawsuit in Harris County District Court. Defendant filed a motion to transfer venue, a general denial, and removed the case to federal court. What discovery tools would be useful in digging deeper into defendant's general denial? Identify two discovery tools that could be used to specifically identify what allegations defendant denies or contends are false.