Interrogatories - Sexual Harassment in the Workplace

Plaintiff’s Questions to Defending Employer

1. State your full name, address, occupation, title, and relationship to the Defendant Company _________________; also, please provide the full name, address, occupation, title, and relationship to the Defendant of each individual who assisted the answering of these interrogatories.

2. With respect to the employment of the Plaintiff, please set forth the following information specifically and in detail:

   1. The Plaintiff’s date of hire.

   2. The Plaintiff’s date of termination and the reason for her termination.

   3. The Plaintiff’s rate of pay on her date of hire, together with her rates of pay after each increase or decrease in pay, and the dates of each such increase or decrease.

   4. For each job that the Plaintiff held, please set forth the dates during which the Plaintiff held each job and provide a description of her job duties during such dates.

   5. A description of the job held by Plaintiff when she commenced work, along a list of each publication, web posting, or advertisement used by the Defendant to advertise the job position.

3. Please provide the name, title or other means of identification of each employee, agent or independent contractor of the Defendant who has custody of statistical information and personnel records indicating the rates of promotion, termination, pay increases and pay decreases for employees who occupied job duties and descriptions similar to those of the Plaintiff.

4. Please identify each writing or document that exists pertaining to the hiring, employment and termination of the Plaintiff, including but not limited to those writings contained within the Plaintiff’s personnel files.

5. Please identify each supervisor or manager who was responsible for overseeing the work of the Plaintiff, and for each such person please provide the following information, specifically and in detail with respect to each:

   1. His or her name, title and gender.

   2. The work station location or office location wherein this person worked.

6. Please identify each writing or document that exists pertaining to the hiring, employment and termination of every person who managed or supervised the Plaintiff, including but not limited to those writings contained within their respective personnel files, and for each such writing, please set forth the following information specifically and in detail:

   1. Its title, date, author, purpose, and a summary of its contents.

   2. The name, address and telephone number of the person who has custody of the document.

7. Please set forth the following information pertaining to the employment of _____________. [The name of the person who harassed the Plaintiff, hereafter “Harasser”]:

   1. His date of hire.

   2. His date of termination if he is no longer employed by the Defendant.

   3. The reason for his termination if he is no longer employed by the Defendant.

   4. His job description and job duties throughout the period of time that the Plaintiff was employed by the Defendant.

   5. The work station location or office location wherein this person worked.

8. Did Plaintiff ever complain to any officer, director, agent or employee of the Defendant about any conduct or misconduct on the part of Harasser? If your answer is anything other than an unqualified “No,” then...