Defendant's First Set of Interrogatories to Plaintiff-FLSA

IN THE UNITED STATES DISTRICT

FOR THE __________ DISTRICT OF TEXAS

__________ DIVISION

________, §

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Plaintiff, § §

§ Civil Action No. ____________

v. §

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________ §

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Defendant. §

DEFENDANT’S FIRST SET OF

INTERROGATORIES TO PLAINTIFF

TO: ________, through his counsel of record, _______________________________:

Pursuant to Federal Rule of Civil Procedure 33, Defendant requests Plaintiff, ________, to provide answers to the attached interrogatories within thirty (30) days after service of this document. You are further requested to supplement your response as required by the Federal Rules of Civil Procedure.

I.

INSTRUCTIONS

1. You should answer each of the following interrogatories separately, in writing and under oath and submit them to counsel for Defendant on or before thirty (30) days after their service.

2. Unless otherwise indicated, the use in these Interrogatories of the name of any party, person, or organization shall specifically include all agents, employees, shareholders, owners, officers, directors, joint venturers, representatives, attorneys and all other persons acting on behalf of the subject party, person, or business organization.

3. For purposes of interpreting or construing the scope of these Interrogatories, all terms shall be given their most expansive and inclusive interpretation, unless otherwise specifically limited by the language of an individual Interrogatory. This includes, without limitation, the following: (a) construing “and” as well as “or” in the disjunctive or conjunctive, as necessary to make the request more inclusive; (b) construing the singular form of the word to include the plural, and the plural form to include the singular; (c) construing the masculine to include the feminine and vice versa; and (d) construing the term “including” to mean “including but not limited to.”

   II.

   DEFINITIONS

1. The term “DOCUMENTS” is used in the broadest sense and includes, but is not limited to, electronic information (as defined below), originals and any non-identical copies or reproductions of any written or recorded matter, whether printed, reproduced by any other mechanical or electronic process, or handwritten, including, but not limited to, drafts of any documents, revisions of drafts of any documents, and original or preliminary notes concerning drafts of any documents, books, accounts, journals, correspondence, memorandum, letters, reports, agreements, communications (including inter- and intra-office and inter- and intra-company communications), e-mails, Internet communications, telegrams, telexes, cables, indices, pictures, blueprints, sketches, plans, drawings, diagrams, projections, bulletins, advertising literature, brochures, pamphlets, circulars, codes as well as other devices to decipher abbreviations or other notations, computer printouts, analytical records, memoranda, summaries, diaries, forecasts, photographs, photocopies, recordings, tape recordings, motion picture films, graphs, note charts, notebooks, charts, minutes, notes or recordings of meetings, documents distributed at, generated for or as a result of meetings, lists of persons attending meetings, records, notes, reports and/or summaries of interviews, conversations, telephone calls, conferences, investigations or negotiations, opinions or reports of consultants, appraisals, press releases, newspaper articles, mailing lists, contracts, agreements, drafts, notes, marginal comments appearing on or affixed to any document, calendars, day-timers, datebooks, messages, letters of credit, financial statements, invoices, statements of account, receipts, promissory notes, security agreements, deeds of trust, instruments purporting to grant or evidencing any security interest or lien, loan agreements, credit and debit memoranda, cancelled checks and drafts (both front and back), check stubs, securities ledgers, and any other papers or writings of any character or...