| OLUWABUNDI AKINYEMI
Plaintiff, v. THE ARC OF BALTIMORE, INC. Defendant. |
IN THE CIRCUIT COURT FOR BALTIMORE COUNTY
Case No.: C-03-CV-20-003847 |
PLAINTIFF’S RESPONSES TO DETENDANT’S F’IRST REQUEST FOR PRODUCTION OT DOCUMENTS AND DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF
COMES NOW, Plaintiff, pro se, and serves these, his responses to Defendant’s Request for Production of Documents and First Set of Interrogatories pursuant to Maryland Rules of Civil Procedure, Rule 2-422, as follows:
OBJECTIONS AND RESPONSES TO REQUEST FOR PRODUCTION
GENERAL OBJECTIONS
Plaintiff objects to each Request: (1) insofar as it calls for the production of documents not in Plaintiff’s possession, custody, or control; (2) insofar as it calls for the production of documents that were prepared for or in anticipation of litigation, constitute attorney work product, contain attorney-client communications, or are otherwise privileged; (3) insofar as it calls for the production of documents which are publicly available or otherwise equally available and/or uniquely available or equally available from third parties; (4) insofar as it calls for the production of documents that do not specifically refer to the events which are the subject matter of this litigation; and (5) insofar as it calls for the production of documents which
are neither relevant to the subject matter of this litigation nor reasonably calculated to lead to the discovery of admissible evidence.
The inadvertent production or disclosure of any privileged documents or information shall not constitute or be deemed to be a waiver of any applicable privilege with respect to such document or information (or the contents or subject matter thereof) or with respect to any other such document or discovery now or hereafter requested or provided. Plaintiff reserves the right not to produce documents that are in part protected by privilege, except on a redacted basis, and to require the return of any document (and all copies thereof) inadvertently produced. Plaintiff likewise does not waive the right to object, on any and all grounds, to (1) the evidentiary use of documents produced in response to these requests; and (2) discovery requests relating to those documents.
Plaintiff submits these responses and objections without conceding the relevancy or materiality of the subject matter of any request or of any document, or that any responsive materials exist.
Plaintiff’s responses and objections are not intended to be, and shall not be construed as, agreement with Defendant’s characterization of any facts, circumstances, or legal obligations. Plaintiff reserves the right to contest any such characterization as inaccurate. Plaintiff also objects to the Requests to the extent they contain any express or implied assumptions of fact or law concerning matters at issue in this litigation.
The responses and objections contained herein are made on the basis of information now known to Plaintiff and are made without waiving any further objections to or admitting the relevancy or materiality of any of the information requested. Plaintiff’s investigation, discovery and preparation for proceedings are continuing and all answers are given without prejudice to Plaintiff’s right to introduce or object to the discovery of any documents, facts or information discovered after the date hereof.
Plaintiff will provide its responses based on terms as they are commonly understood, and consistent with the Maryland Rules of Civil Procedure. Plaintiff objects to and will refrain from extending or modifying any words employed in the requests to comport with expanded definitions or instructions.
DOCUMENT REOUEST NO. 1. All documents referred to in your Answers to Interrogatories or utilized in preparing your Answers to Interrogatories.
RESPONSE:
Plaintiff objects to this request as overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO. 2. All documents referenced in your Compliant.
RESPONSE:
See attached.
DOCUMENT REOUEST NO.3. All written or recorded statements (as that term as used in Rule 2-402(f)), which were previously made by Plaintiff or Defendant and any of its present or former directors, officers, or employees, concerning this action or the occurrence.
RESPONSE:
Plaintiff objects to this request as it seeks discovery of documents that are already in the possession of the Defendant. Further Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO. 4. All documents (including, but not limited to, fee agreements, reports, and correspondence) provided to, received from, or prepared by each witness identified in your Answers to Interrogatories who has been retained or specially employed to provide expert testimony in this case and whom you expect to testify at trial.
RESPONSE:
Plaintiff objects to this request as overly broad, unduly burdensome, vague, and not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff objects to this request on the ground that it seeks information and documents protected from disclosure by privacy laws.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant non-privileged documents that are responsive to this request to the extent permitted by law on a rolling basis as they become available.
DOCUMENT REOVEST NO. 5. All transcripts of prior testimony or each expert expected to testify at any hearing or trial in this matter.
RESPONSE:
Defendant is currently not in the possession, custody or control of any documents responsive to this request.
DOCUMENT REOUEST NO.6. All reports, notes, calculations and other documents prepared by each expert whom you intend to call as a witness at any hearing or trial in this matter.
RESPONSE:
Defendant is currently not in the possession, custody or control of any documents responsive to this request.
DOCUMENT RSOUEST NO. 7. The current resume or curriculum vitae of each expert expected to testify at any hearing or trial in this case.
RESPONSE:
Defendant is currently not in the possession, custody or control of any documents responsive to this request.
DOCUMENT REOUEST NO.8. All documents concerning your claim for damages or the methods used to calculate such alleged damages.
RESPONSE:
Plaintiff objects to this request as overly broad, unduly burdensome and that that it seeks information and documents protected from disclosure by privacy laws.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant non-privileged documents that are responsive to this request to the extent permitted by law on a rolling basis as they become available.
DOCUMENT REOUEST NO. 9. All documents received from or provided to any other party to this action since the filing of the Complaint, whether provided formally or informally or in response to a formal request.
RESPONSE:
Plaintiff objects to this request as it seeks discovery of documents that are already in the possession of the Defendant. Further Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO. 10. All documents concerning any release, settlement, or other agreement, formal or informal, pursuant to which the liability of any person or entity for damage arising out of the occurrence which is the subject matter of this lawsuit has been limited, reduced, or released in any manner. This request includes all agreements by one party or person to indemnify another party or person for claims asserted in this action.
RESPONSE:
Plaintiff objects to this request as it seeks discovery of documents that are already in the possession of the Defendant. Further Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT RDOUEST NO. 11. All documents you intend to or may introduce as exhibits in any evidentiary hearing or trial conducted in this matter.
RESPONSE:
See attached.
DOCUMENT REOUEST NO. 12. All documents and/or communications (including, but not limited to, correspondence, notes, memoranda, and journal entries) which relate to, describe, summarize, or memorialize any communication between you and anyone at Defendant, or anyone known or believed by you to have been acting under the authority of Defendant, that form the basis of any claim in your Complaint that have not been otherwise requested above.
RESPONSE:
Plaintiff objects to this request as it seeks discovery of documents that are already in the possession of the Defendant. Further Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO. 13. All documents received from any non-party since the filing of the Complaint, whether provided formally or informally or in response to a formal request or subpoena that concern the claims or relief sought in the Complaint.
RESPONSE:
Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO.14. Any documents or other tangible things you obtain in response to any subpoena duces tecum issued in this case.
RESPONSE:
Defendant is not in the possession, custody or control of any documents responsive to this request.
DOCUMENT REOUEST NO. 15. A11 documents and/or communication relating to, referring to, or concerning your employment history from 2015 to present, including pay stubs, job classification sheets, employee notices, personnel payroll records, 1099-R, 1099 MISC, Schedule C form 1040 along with all other schedules and IRS forms 1040, 1040 EZ and/or all other tax forms showing all income from self-employment and income as an employee.
RESPONSE:
Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO. 16. All documents and/or communication relating to, referring to, or concerning employment benefits that you received or that were offered to you during your employment with Defendant.
RESPONSE:
Plaintiff objects to this request as overly broad, unduly burdensome. The request also seeks disclosure of information already in the possession of the Defendant and documents protected from disclosure by privacy laws.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant non-privileged documents that are responsive to this request to the extent permitted by law on a rolling basis as they become available.
DOCUMENT REQUEST NO. 17. All contacts of employment involving you (whether as an “employee” or independent contractor”) and any employer, third person or entity, at any time from 2016 to present.
RESPONSE:
Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO. 18. Copies of your federal and state personal income tax returns, W-2 forms, and 1099 forms/statements from 2016 to present.
RESPONSE:
Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO. 19. A1l records of any income or funds received by you from 2016 to present, including but not limited to any salary or other compensation, commissions, bonuses, draws, loan advances, or any other funds of any kind or description received by you.
RESPONSE:
Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO.20. A copy of all medical records related to treatment you received from physicians, therapists or other practitioners relevant to the Complaint.
RESPONSE:
Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO. 21. A copy of all documents and/or communications with the Maryland Department of Health relevant to the Complaint.
RESPONSE:
Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO. 22. All logs, diaries, calendars and similar records in paper or electronic form in which you recorded information relevant to the Complaint.
RESPONSE:
Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REOUEST NO.23. All photographs, video, or audio recordings taken of any conduct that relates to the Complaint.
RESPONSE:
Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
DOCUMENT REQUEST NO. 24. All documentation relating to your communications with Defendant, and/or discussions with your coworkers about the allegations in the Complaint, including posts on Facebook, tweets, texts, or other electronically transmitted communications.
RESPONSE:
Plaintiff objects to this request as it is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific insofar as it requests documents “relied upon” in responding to the United States’ interrogatories. Plaintiff objects to the extent the request seeks the production of documents that are not relevant or likely to lead to the discovery of admissible evidence. Plaintiff further objects to the extent that this request calls for the production of documents subject to attorney-client privilege, deliberative process privilege, and attorney work-product protection. Plaintiff objects to this request on the ground that it seeks documents and information protected from disclosure by Maryland laws. Plaintiff objects to this request to the extent that it calls for the production of documents within the control of third parties, whose documents are not within Plaintiff’s possession, custody, or control.
Subject to and without waiving the foregoing objections, Plaintiff will produce relevant, non-privileged documents that are responsive to this request on a rolling basis as they become available.
OBJECTIONS AND RESPONSES TO FIRST SET OF INTERROGATORIES
GENERAL OBJECTIONS
By providing information in response to these Interrogatories, Plaintiff does not concede the accuracy of Defendant’s definitions, assumptions or allegations. Nor does Plaintiff concede that any of the information sought is admissible, material or relevant in these proceedings. Plaintiff does not waive any general or specific objections by providing a response to any of the Interrogatories.
Plaintiff has made a reasonable, good-faith inquiry into the subject matter of each Interrogatory. Plaintiff’s responses are based on the facts reasonably ascertainable to Plaintiff. Plaintiff reserves the right to modify or amend these responses at any time and as discovery proceeds.
Plaintiff objects to these Interrogatories to the extent that they call for information that is protected by the attorney-client privilege, the work product doctrine, or any other privilege or protection recognized by law.
Plaintiff objects to these Interrogatories to the extent they attempt to impose burdens and requirements beyond those required by the Maryland Rules of Civil Procedure.
Plaintiff’s responses shall not be construed in any way as an admission that any definition provided by Defendant is either factually correct or legally binding upon Plaintiff or a waiver of any of Plaintiff’s objections regarding relevancy, discoverability and admissibility.
Plaintiff reserves the right to supplement these responses and objections.
INTERROGATORY NO. 1: Identify each person, other than a person intended to be called as an expert witness at trial, having discoverable information that tends to support a position that you have taken or intend to take in this action, including any claim for damages, and state the subject matter of the information possessed by that person. (Standard General Interrogatory No. 1.)
RESPONSE:
None. Only Plaintiff will testify as to the allegations in the Complaint.
INTERROGATORY NO. 2: Identify each person whom you expect to call as an expert witness at trial, state the subject matter on which the expert is expected to testify, state the substance of the findings and opinions to which the expert is expected to testify and a summary of the grounds for each opinion, and, with respect to an expert whose findings and opinions were acquired in anticipation of litigation or for trial, summarize the qualifications of the expert, state the terms of the expert’s compensation, and attach to your answers any available list of publications written by the expert and any written report made by the expert concerning the expert’s findings and opinions. (Standard General Interrogatory No. 2.)
RESPONSE:
None. Plaintiff has not retained an expert witness but reserves the right to do so as discovery proceeds. Further, Plaintiff specifically reserves the right to call as an expert any and all expert witnesses identified by Defendant.
INTERROGATORY NO.3: If you intend to rely on upon any documents, electronically stored information, or tangible things to support a position that you have taken or intent to take in the action, including any claim for damages, provide a brief description by category and location, of all such documents, electronically stored information, and tangible things, and identify all persons having possession, custody, or control of them. (Standard General Interrogatory No. 3.)
RESPONSE:
Plaintiff objects to this Request on the grounds that the information requested is personal and confidential and not and not proportional to the needs of the case. Plaintiff further objects to this Request as it is overly broad and cumbersome. If Defendant limits the scope of this Request to specifically identifiable documents relevant to this matter, Plaintiff may be able to respond.
INTERROGATORY NO. 4: Itemize and show how you calculate any economic damages claimed by you in this action, and describe any non-economic damages claimed. (Standard General Interrogatory No. 4.)
RESPONSE:
Plaintiff incorporates herein by reference his response to Defendant’s Document Request Number 8 above.
INTERROGATORY NO. 5: State your name and any other names by which you have been known and list all residences in which you have lived over the past 10 years, giving the dates in which lived at each residence.
RESPONSE:
Plaintiff objects to this Request on the grounds that the information requested is personal and confidential and not and not proportional to the needs of the case. Plaintiff further objects to this Request as it is overly broad and cumbersome.
INTERROGATORY NO. 6: Identify all persons who have given you “statements,” as that term is defined in Rule 2-402 (f), concerning the action or its subject matter. For each statement, state the date on which it was given and identify the custodian.
RESPONSE:
Plaintiff objects to this Request on the grounds that the information requested is confidential and is overly broad and cumbersome. If Defendant limits the scope of this Request to specifically identifiable documents relevant to this matter, Plaintiff may be able to respond.
INTERROGATORY NO. 7: Identify your employment history from high school to present, specifying the length of time you stayed at each job including any periods of unemployment and for each position held state your position, salary and benefits and the reason you left each position and the name and address of your supervisor.
RESPONSE:
Plaintiff objects to this Request on the grounds that the information requested is unreasonable, overly broad and cumbersome. If Defendant limits the scope of this Request to specifically identifiable information relevant to this matter, Plaintiff may be able to respond.
INTERROGATORY NO. 8: Have you ever been arrested, charged or convicted of a crime? If so, provide the date of the arrest, charge or conviction, the related charge(s), case number and the jurisdiction in which the case was brought.
RESPONSE:
None.
INTERROGATORY NO. 9: Identify all communications, written or oral, you have had with any person (including Defendant) concerning the subject matter of the Complaint. If you allege a verbal communication, please state the place and date of the communication, the name of the person who you communicated with, the person who initiated the communication, manner (e.g., telephone, e-mail, face-to-face) of communication, and the substance of the communication.
RESPONSE:
Plaintiff objects to this Request on the grounds that the information requested is overly broad and cumbersome. Plaintiff further objects to this Interrogatory as it seeks information that is already in possession of Defendant and irrelevant. If Defendant limits the scope of this Request to specifically identifiable information relevant to this matter, Plaintiff may be able to respond.
INTERROGATORY NO. 10: If you contend that the Defendant or its agents, officers, directors, representatives, employees, made any statement which could be construed as an admission against interest, for each such statement identify, the person making the statement, the date of the statement and a description of the nature and contents of the statement.
RESPONSE:
Plaintiff withholds his response to this interrogatory pending his receipt of Defendant’s response to Plaintiff’s discovery requests.
INTERROGATORY NO. 11: State with specificity the factual and legal basis for each and every claim that you have asserted or intend to assert in this matter.
RESPONSE:
Plaintiff objects this interrogatory as it seeks a restatement of Plaintiff’s allegations in Plaintiff’s Complaint, and any subsequent Plaintiff’s pleading in this case. Accordingly, Plaintiff refers Defendant to Defendant’s record of Plaintiff’s Complaint and all Plaintiff’s pleadings filed in this case.
INTERROGATORY NO. 12: Identify all promotions, job titles, pay raises and bonuses you held or received during your employment with Defendant.
RESPONSE:
Plaintiff objects to this Interrogatory as this information is already in possession of Defendant and irrelevant. If Defendants limit the scope of this Interrogatory to relevant and timely information, Plaintiff will provide a response.
INTERROGATORY NO. 13: Have you been a party as plaintiff or defendant in any action, suit or proceeding (other than this one) brought or made in any in any court, administrative, or arbitration proceeding? If you answer in the affirmative, identify the nature of the proceeding and provide the relevant case number and the jurisdiction in which the proceeding was brought.
RESPONSE:
None.
INTERROGATORY NO. 14: Set forth with particularity your reasons for submitting to a COVID-l9 test on or about August 6,2020 and include in your response a detailed description of all symptoms that you exhibited prior to the test.
RESPONSE:
Plaintiff objects to this Request on the grounds that the information requested is personal and confidential and not and not proportional to the needs of the case.
INTERROGATORY NO. 15: Identify and describe in detail all communications that you had with any health care provider, including the Maryland Department of Health, concerning your
COVID-l9 test on or about August 6, 2020 and related treatment. If you allege a verbal communication, please state the place and date of the communication, the name of the person who you communicated with, the person who initiated the communication, manner (e.g., telephone, e-mail, face-to-face) of communication, and the substance of the communication.
RESPONSE:
Plaintiff objects to this Request on the grounds that the information requested is personal and confidential and not and not proportional to the needs of the case.
INTERROGATORY NO. 16: Set forth with particularity your employment status with Defendant, including whether you were a full-time or part-time employee, and set forth the average weekly hours that you worked for Defendant in each year between 2At6-202A and identify all benefits that you received from Defendant or was eligible to receive from the Defendant.
RESPONSE
Plaintiff objects to this Interrogatory as this information is already in possession of Defendant.
INTBRROGATORY NO. 17: State fully, completely, and at length the factual basis in support of your allegation in Paragraph 43 of the Complaint that “At the time of the termination of her employment, Plaintiff had accrued but unused paid leave of approximately 200 hours.”
Your response should explain the basis of your knowledge and identify all documents relating to this allegation. If the basis for the allegation is a communication, your response should identify the person making the communication, the date of the communication and a description of the nature and contents of the communication.
RESPONSE:
Plaintiff objects to this Interrogatory as this information is already in possession of Defendant.
INTERROGATORY NO. l8: State fully completely, and at length the factual basis in support of your contention in Paragraph 44 of the Complaint that your “Defendant willfully refused to pay Plaintiff for her unused paid leave.” Your response should explain the basis of your knowledge and identify all documents relating to this allegation. If the basis for the allegation is a communication, your response should identify the person making the communication, the date of the communication and a description of the nature and contents of the communication.
RESPONSE:
Plaintiff objects to this Interrogatory as this information is already in possession of Defendant.
INTERROGATORY NO. 19: Do you contend that you notified Defendant of or made a request to Defendant for leave pursuant to the FMLA? If you answer affirmatively, state fully,
completely, and at length the factual basis for this contention. Your response should identify all documents relating to this allegation. If the basis for the allegation is a communication, your
response should identify the persons involved in the communication, the date of the communication and a description of the nature and contents of the communication.
RESPONSE:
Plaintiff objects to this Interrogatory as this information is already in possession of Defendant. Plaintiff further contends that the information sought is overly broad and cumbersome. If Defendants limit the scope of this Interrogatory to relevant and timely information, Plaintiff will provide a response.
INTERROGATORY NO. 20: State fully, completely, and at length the factual basis in support of your contention in Paragraph 38 of the Complaint that “Defendant retaliated against
Plaintiff by suspending and terminating Plaintiff s employment”. Your response should explain the basis of your knowledge and identify all documents relating to this allegation. If the basis for the allegation is a communication, your response should identify the person making the
communication, the date of the communication and a description of the nature and contents of the communication.
RESPONSE:
Plaintiff objects to this Interrogatory as this information is already in possession of Defendant.
INTERROGATORY NO. 21: Identify the name of your family physician(s)/primary care physician(s) during the last ten (10) years.
RESPONSE:
Plaintiff objects to this Interrogatory as this information is overly broad and cumbersome. If Defendants limit the scope of this Interrogatory to relevant and timely information, Plaintiff will provide a response.
INTERROGATORY NO. 22: During your employment with Defendant have you had or do you currently have any social media accounts such as Facebook, Instagram, Twitter, etc.? If so, identify all such social media accounts.
RESPONSE:
Plaintiff objects to this Request on the grounds that the information requested is personal and confidential and not and not proportional to the needs of the case Plaintiff further objects to this Request as it seeks information not relevant to the allegations in Plaintiff’s Complaint. If Defendant limits the scope of this Request to a time frame (or specific subject matter) relevant to this matter, Plaintiff may be able to respond.
Dated: ______________
Respectfully Submitted,
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was sent on the [DAY] day of [MONTH] [YEAR] by regular U.S. mail, by facsimile, or certified mail, return receipt requested, to the following parties or attorneys of record:
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