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Plaintiff's "Triple Threat" Discovery to Defendant in Age Discrimination Case
[Style of Case]
PLAINTIFF'S FIRST REQUESTS FOR ADMISSIONS, FIRST SET OF
INTERROGATORIES AND FIRST REQUESTS FOR PRODUCTION
OF DOCUMENTS PROPOUNDED TO DEFENDANT
TO: Defendant _____, by and through its registered agent for service of process:
Pursuant to the [Federal/Texas] Rules of Civil Procedure, Plaintiff _____ (hereafter "Plaintiff") submits to Defendant _____ (hereafter "Defendant") the following discovery.
[INSERT STANDARD INSTRUCTIONS & DEFINITIONS, FORM DIS016]
USE NOTE: Some of the interrogatories below seek information that must be provided pursuant to the disclosure requirements in the Federal and Texas Rules of Civil Procedure. Since the rules of procedure limit the number of interrogatories a party can propound, you may wish to forego sending some of the interrogatories listed below.
Also note that some of the interrogatories below that seek all "facts, proof, and evidence" to support a claim may seek excessive information under the Texas Rules of Civil Procedure, which do not require a party to "marshall all of its available proof or proof the party intends to offer at trial." See Tex. R. Civ. P. 197.1
REQUESTS FOR ADMISSIONS
[INSERT STANDARD REQUESTS FOR ADMISSIONS, FORM DIS018]
[Additional Requests for Admissions tailored specifically for an age discrimination case are listed below.]
ADMISSION NO. :Admit that _____ was under the age of 40 at the time Plaintiff was [insert adverse action was taken against Plaintiff, e.g., demoted, fired].
RESPONSE:
ADMISSION NO. :Admit that at the time of the [insert adverse action taken against Plaintiff] you employed more than _____ employees at the _____.
RESPONSE:
ADMISSION NO. : Admit that at the time Plaintiff's salary was reduced from $_____ to $_____ a year, Defendants wanted to develop a younger customer base at _____.
RESPONSE:
ADMISSION NO. : Admit that at the time _____ became _____ , [he/she] was _____ years of age.
RESPONSE:
ADMISSION NO. : Admit that _____ was _____ years old when [he/she] was hired to work at _____.
RESPONSE:
ADMISSION NO. : Admit that when _____ interviewed _____, [he/she] asked _____ how old [he/she] was.
RESPONSE:
ADMISSION NO. : Admit that at the time Plaintiff's employment relationship with _____ ended, Plaintiff had been employed by _____ for more than _____ years.
RESPONSE:
ADMISSION NO. : Admit that _____ demoted Plaintiff from _____ to _____ and that an employee aged _____ replaced Plaintiff as _____.
RESPONSE:
ADMISSION NO. : Admit that...
To continue reading
Request your trial- Appendices
- Discovery Forms
- Medical records authorization
- Authorization for Texas Worker’s Compensation Commission Records
- Employment Records Authorization
- Scholastic Records Authorization
- Military Records Authorization
- Oral and Video Deposition Duces Tecum Propounded to Defendant for Employment Cases in General
- Oral and Video Deposition Duces Tecum to Plaintiff for Employment Cases in General
- Deposition Duces Tecum Propounded to Defendant City, Whistleblower Case
- Deposition Outline Checklist: Plaintiff’s Deposition of Defendant’s Employees: General Questions
- Deposition Checklist: Deposing the Plaintiff in Employment Cases (In General)
- Deposition Outline (Plaintiff) - False Imprisonment
- Standard Responses, Objections, and Answers to Interrogatories For Defendants and Plaintiffs
- Standard Responses, Objections, and Answers to Request for Production of Documents for Both Defendants and Plaintiffs
- Standard Instructions and Definitions for Defendant’s Written Discovery to Plaintiff
- Defendant's "Triple Threat" Discovery Propounded to Plaintiff in Employment Cases in General
- Defendant's "Triple Threat" Discovery Propounded to Plaintiff Employee's Spouse
- Sworn Statement by Non-Managerial Employee of Defendant
- Standard Instructions and Definitions for Plaintiff's Written Discovery to Defendant
- Plaintiff's "Triple Threat" Discovery to Defendant in Age Discrimination Case
- Plaintiff's Standard "Triple Threat" Discovery to Defendant in Employment Cases in General
- Plaintiff's "Triple Threat" Discovery Propounded to Defendant in Sexual Harassment Case
- Plaintiff's First Request for Production of Documents Propounded to Defendant City in a Whistleblower Case
- FOIA Request to the EEOC
- Open Records Request to the TCHR
- Standard Responses, Objections, and Answers to Interrogatories for Defendants and Plaintiffs Under Texas Rules of Civil Procedure
- Standard Responses, Objections and Answers to Request for Production of Documents for Defendants and Plaintiffs Under Texas Rules of Civil Procedure
- Request for Disclosures (Short Form) (State)
- Request for Disclosures (Long Form) (State)
- Discovery Plan (Worksheet)
- Deposition Outline - Economist
- Deposition Outline - Medical/Mental Health Professional
- Plaintiff's Proposed Pattern Interrogatories and Request for Production
- Level Three Discovery Control Plan
- Authorization for Release of Financial Records
- Motion to Compel Discovery (State)
- Deposition Outline - Corporate Representative - Products Liability
- "About Your Upcoming Deposition"
- Defendant's "Triple Threat" Discovery to Plaintiff - Race, Age & Firing
- Defendant's "Triple Threat" Discovery to Plaintiff - Sexual Harassment and Firing
- Plaintiff's "Triple Threat" Discovery to Defendant - Sex Discrimination (State Court)
- Plaintiff's "Triple Threat" Discovery to Former Employee Stealing Trade Secrets
- Petition Requesting Deposition Before Suit
- Opposition to Pre-Suit Deposition
- Order Authorizing Deposition
- Defendant's First Set of Interrogatories to Plaintiff-FLSA
- Defendant's First Set of Requests for Production to Plaintiff-FLSA
- Plaintiff's Triple-Threat to Defendant re: Stealing Trade Secrets
- Request For Disclosure To Defendant-FMLA, ADEA
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