UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
SHERMAN DIVISION
| CHELSA S. BROWNPlaintiff, V. THE RENY COMPANYDefendant. | PLAINTIFF’S RESPONSE TO DEFENDANT’S FIRST SET OF INTERROGATORIES. |
RESPONSE TO INTERROGATORIES
RESPONSE TO INTERROGATORY NO. 1
All information requested under interrogatory no. 1 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to interaction with other individuals can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 2
All information requested under interrogatory no. 2 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to interaction with other individuals can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 3
All information requested under interrogatory no. 3 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to interaction with other individuals can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 4
Plaintiff is unable to respond to interrogatory no. 4 as the information requested does not exist.
RESPONSE TO INTERROGATORY NO. 5
All information requested under interrogatory no. 5 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to medical treatment in any manner shape or form can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 6
All information requested under interrogatory no. 6 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information with respect to interrogatory no. 6 can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 7
All information requested under interrogatory no. 7 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to actual damages, consequential damages, emotional distress, loss of professional reputation, humiliation, and loss of enjoyment of life can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 8
All information requested under interrogatory no. 8 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to the medical condition of the Plaintiff can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 9
RESPONSE TO INTERROGATORY NO. 10
RESPONSE TO INTERROGATORY NO. 11
RESPONSE TO INTERROGATORY NO. 12
RESPONSE TO INTERROGATORY NO. 13
RESPONSE TO INTERROGATORY NO. 14
All information requested under interrogatory no. 14 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to the Plaintiff’s disabilities can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 15
All information requested under interrogatory no. 15 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to the Plaintiff’s disabilities can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 16
All information requested under interrogatory no. 16 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to the Plaintiff’s disabilities can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 17
All information requested under interrogatory no. 17 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to the Plaintiff’s Medicare status can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 18
All information requested under interrogatory no. 18 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining to the Plaintiff’s treatment as an employee can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 19
All information requested under interrogatory no. 19 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 20
All information requested under interrogatory no. 20 is produced in the Plaintiff’s complaint, list of disclosures, and all other evidence produced by the Plaintiff individually and in compliance with any discovery requests. No further information pertaining persons consulted by the Plaintiff can be ascertained by the Plaintiff.
RESPONSE TO INTERROGATORY NO. 21
Pursuant to the Family Medical Leave Act, an employee is entitled to twelve workweeks of leave in a 12-month period for a serious health condition that makes the employee unable to perform the essential functions of his or her job. Plaintiff was diagnosed with the Covid-19 virus, which virus has caused a global pandemic. Upon testing positive, Plaintiff was not allowed the benefit of the provisions of the Family Medical Leave Act and was instead issued with a termination notice prior to lapse of the 12-week period.
DATED: [insert date]
Respectfully submitted,
________________________________
Chelsa Brown
6201 Chapel Hill Blv., #116
Plano, TX 75093.
Pro Se Litigant
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