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Discovery: Interrogatories






NAOMI REDACTED, Plaintiff, vs. REDACTED, INC., Defendant. CASE NO.: 5:11-cv-375-OC-10DAB




PLEASE TAKE NOTICE that pursuant to the Federal Rules of Civil Procedure, Defendant, Redacted serves upon the Plaintiff, Naomi Redacted (“You” or “Plaintiff”) its initial Interrogatories which are required to be answered in writing and under oath within thirty (30) days from the date of service hereof.


  1. The term “person” means any natural person, any business entity (whether a corporation, partnership, or other business association), any government or political subdivision thereof, or governmental body, commission board, agency, bureau, or department.

  2. The terms “document” or “documents” mean the original and all copies thereof which are different in any way from the original (whether by interlineation, receipt stamps notation, indication of copies sent or received, or otherwise) and all attached or annexed materials to any written, typewritten, handwritten, printed, graphic, photographic or recorded material as well as

all computer data files, tapes, disks, inputs or outputs, and other computer-readable records or programs, transcripts and copies and reproductions thereof, however produced or reproduced, now or at any time in your actual or constructive possession, custody or control. The terms “document’ or “documents” shall specifically include, but not be limited to, correspondence, telegrams, facsimiles, telexes, memoranda, memoranda or records of meetings, conferences, telephone or other communications, pamphlets, books, notes, reports, studies, transcripts, indexes, accounting records of any kind, including bank examination reports whether state of federal, filings, records, charts, tabulations, lists, analyses, graphs, diagrams, estimates, minutes, (including board and loan committee minutes), tapes, photographs and photographic films, sound recording tapes, phonograph records, video tapes, data compilations form which information can be obtained or can be translated into a form reasonably usable, as well as any method of electronic data processing or magnetic tape storage medium, including the printed output of any such electronic data processing equipment or magnetically stored information.

  1. The term “things” means tangible or intangible property not otherwise defined as a document.

  2. The term “copy” when used in reference to a document means any color or black-and-white facsimile reproduction of a document, regardless or whether the facsimile reproduction of a document, regardless of whether the facsimile reproduction is made by means of carbon paper, pressure sensitive paper, xerography or other means or process.

  3. The terms “identify” or “identification” when used in reference to an individual person mean to state his full name, present address, if known, and his present employment position and business affiliation. When used in reference to a person other than an individual person, “identify” or “identification” means to state whether such a person is corporation, partnership, or other organization, and the name, present or last known address, and the principal place of business thereof. Once any person has been identified properly it shall be sufficient thereafter when identifying that same person to state his name only.

  4. The term “communication” means any writing, or oral conversation, including, but not limited to, telephone conversations and meetings, letters, facsimile, telegraphic, and telex communications.

  5. The term “information” means data of any kind recorded in any language, including machine language and recorded numerically, and in any form of expression.

  6. The term “act” means an act, transaction, decision, communications, statement, conduct, meeting, or any other type of event or occurrence (hereinafter collectively referred to as “act”), and your response should include, but not be limited to, the following:

a. The date of the act;

b. The place where the act occurred;

c. The identification of the parties thereto and any other persons present, consulted or otherwise involved, together with any firm or corporation on whose behalf each such person acted or purported to act, and in the case of any type of communication, oral or written, specify the sender and the recipient;

d. The substance and nature of the act; and

e. The identification of all documents pertaining to the act.

  1. The terms “and” and “or” shall be construed conjunctively rather than disjunctively, as is necessary to make each interrogatory inclusive rather than exclusive.

  2. The phrase “pertaining or relating” means being connected or associated, or referring to something.

  3. The term “produce” means to make available the documents or things requested herein for inspection and copying, and to separate such documents into the categories set forth in this request.

  4. To the extent that you consider any of the following requests or questions objectionable, respond to so much of each, and each part thereof, which is not objectionable in your view, and separately state that part of each which is objectionable and the ground for each objection.

  5. When identification of a document is required, your response should include such information as is sufficient to enable the Plaintiff to form an intelligible request for production of such a document with the degree of specificity required by Rule 1.340 of the Rules of Civil

Procedure, and if no copy of the document identified is in your possession, custody, or control,

the name and address of the person now having possession, custody, or control of the document or any copy thereof.

  1. When identification of documents is called for, in lieu of such identification, you may, at the time you respond, produce for inspection and copying such documents or clearly legible copy of the documents to your response and designate in your response, “See Attached Exhibit ____”.

  2. When a statement of the date or time of occurrence of a given event is require, and the exact date or time is not known, your response should state the approximate date or time and that the answer is an approximation.

  3. When a description of a place or location is required, the response should include the street address, name of the person occupying such address, and when applicable, the room and/or floor number.

  4. Your duty to respond is continuing. If, subsequent to your responses and/or your providing any of the documents requested herein, you obtain, discover, acquire, or otherwise cause to possess, in any manner, and other information or documents subject to this request, you are required to submit a supplemental response disclosing this information, and to make any documents available for inspection and copying by the undersigned attorney at such reasonable time as agreed upon between counsel for the parties.


If you object to any discovery request on the basis of attorney-client or work-product privilege, state the privilege claimed and identify the document or communication for which such privilege is claimed, stating the following:

a. The date thereof;

b. The description of the document or communication protected, including the identity of all persons present, if an oral communication; or all persons who received a copy of such communication, if written; and

c. The subject matter of the document or communication.



  1. Identify the full names, titles, addresses, and telephone numbers of any persons who have provided you with information or assistance in answering these interrogatories.



  1. Identify each and every job or work that has provided you with a source of income from February 26, 2006, to the present. For each such job or source of income, state with particularity:

a) the address and telephone of your employer or the person form whom services were rendered;

b) the position(s) you held or the type of service rendered and the date(s) of each change of position;

c) the dates of commencement and cessation of your employment;

d) the name and last known address of your supervisor in each such job;

e) the rate of pay your received in each such employment or source of income, including (1) the date such rate of pay commenced; and (2) the amount an effective date of any changes in the pay rate;

f) all benefits to which you are or were entitled, incluing: (1) name of the benefit plan; (2) date you were eligible to participate in the plan; and (3) nature of the benefit provided; and

g) identify the plan documents for all benefit plans identified in subparagraph (f) above.


  1. Please state the names, addresses and telephone numbers of any and all present or former employees of DEFENDANT that you, your representative or anyone acting on your behalf has contacted and/or communicated with or interviewed regarding the claims made in your complaint. With respect to each such person identified state:

a. the name, address and telephone number of the person;

b. when the person was contacted;

c. whether the person provide a written statement;

d. whether the communication with the person was recorded;

e. what the person said concerning the subject matter of this litigation;

f. identify all documents or other physical evidence, including but not limited to, recordings, emails and computer diskettes which relate to these communications; and

g. identify the person who contacted the individual who was interviewed or questioned.



  1. State whether you have been involved in any litigation other than the present litigation against the defendant, including but not limited to, litigation concerning any previous employer and/or any prospective employer and any bankruptcy proceedings.


  1. State whether you have ever filed any employment-related charge of discrimination or complaint, either formally (with any city, county, state, or federal agency) or informally (using an employer’s internal procedure). If so, state the date of the charge or complaint, the name of the employer involved, the nature of the charge or complaint, and identify the agency with which the charge or complaint was filed and the results of the charge.


  1. State whether you have ever filed for unemployment compensation from any state or local agency at any time. If so, state when you applied for unemployment, the employer, the date you applied for unemployment, the agency with which the request was filed, and the results of the request.



  1. State whether you have ever filed for social security or disability benefits from any state, federal or local agency at any time. If so, state when you applied for the benefits, date you applied for benefits, the agency with which the request was filed, and the results of the request.


  1. State the name, address, and area of specialization, if any, of every physician, psychologist, psychiatric social worker, or any other health, medical, and/or mental care professional you have seen or consulted with respect to any physical or mental condition at any time from February 26, 2006, to the present. For each such person, please state the date of each visit or consultation and identify the treatment that was given, prescribed or recommended.



  1. Identify all internet bulletin boards, discussion boards, chat rooms, friend and professional networks, ie. Linked-in, Facebook, Myspace, or any other social networking sites, in which you have participated since February 26, 2006, and provide all user names that you have used.


  1. Identify all internet service providers, and all e-mail accounts and addresses you have used since February 26, 2006.



  1. State all income from any source you have earned from February 26, 2006, to the present. “Income” is defined as money, compensation, forgiveness of debt, or any other thing of value. Identify by name and address the source of all such income, the amount of the income and the dates during which such income was earned. Also, identify each and every document which supports , relates or reflects your answer to this interrogatory.



  1. Identify each and every document (including recordings, voicemails or electronically stored media such as emails), which refers to, supports or relates to your allegations against the DEFENDANT in the complaint, including the damages sought in the complaint and for each document identified, state the allegations, by paragraph number in the complaint which it supports.



  1. State with specificity each and every category of damages (including, but not limited to back pay, front pay, interest on pay, bonuses, other benefits, etc) you claim to have suffered as a result of Defendant’s alleged conduct. With respect to any such damages claimed:

a) identify the category of the alleged damages;

b) state how said amount is or will be calculated;

c) with regard to any damages claimed, identify what conduct of Defendant, if any, caused such “damages”, and

d) identify any documents relied upon in answering this interrogatory or which in any way support, relate to or reflect your claim for these damages.



  1. State whether you received any medical treatment or medical care, including psychiatric or psychological treatment or counseling, which either you claim, or a healthcare professional has attributed to, the incidents which are the subject of your Complaint. If the answer is in the affirmative, describe in detail:

a) The nature of such care and treatment received;

b) The name and address of any hospital, clinic, or other institutions to which you were admitted for such care and treatment and the dates you were admitted;

c) The number of such examinations or treatments;

d) The name, telephone number and address of any doctor or healthcare professional by whom you were examined or treated, and when and where each such examination or treatment took place; and

e) The diagnosis and prognosis rendered by any such doctor or healthcare professional as a result of any such examination or treatment.




  1. Separately identify each and every person who is known or believed by you to have witnessed the events and /or have knowledge of any facts or material upon which you base the allegations contained in your complaint, and for each such person, summarize the nature and substance of their knowledge.


  1. As alleged in paragraph 16 of your amended complaint, please state exactly what Defendant’s owner told you and/or what you told her during the alleged interview process.


  1. As alleged in paragraph 18 of your amended complaint, identify by name, phone number and address the alleged leasing consultant and manager whom decided to leave the company.


  1. As alleged in paragraph 19 of your amended complaint, who is the male you claim was hired to replace you?

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