Plaintiff's "Triple Threat" Discovery to Defendant - Sex Discrimination (State Court)

PLAINTIFF’S FIRST SET OF INTERROGATORIES, FIRST REQUESTS FOR

ADMISSIONS AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

PROPOUNDED TO DEFENDANT

TO: Defendant ____________, by and through its President:

_________________

_________________

_________________

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(Insert instructions and definitions, etc.)

INTERROGATORIES

INTERROGATORY NO. 1: Identify all employees who worked for you in the same office as Plaintiff if they were employed by you at any time when Plaintiff was employed by you.

ANSWER:

INTERROGATORY NO. 2: Identify all of your employees who at any time were supervised by ______________.

ANSWER:

INTERROGATORY NO. 3: Please identify all of your female employees who have been terminated within the last 10 years for cause.

ANSWER:

INTERROGATORY NO. 4: For each of the employees identified in response to the immediately preceding interrogatory, identify the grounds alleged by you for the termination.

ANSWER:

INTERROGATORY NO. 5: Please describe the work performance of Plaintiff while she/he was employed with you.

ANSWER:

INTERROGATORY NO. 6: Describe any negative entries in ___________’s personnel file including, but not limited to all reprimands, warnings, disciplinary actions, probation, complaints, or any type of disciplinary action taken against ___________.

ANSWER:

INTERROGATORY NO. 7: Describe the process by which employees can air complaints, voice concerns, or report violations of state or federal statutes which an employee has observed during the course of employment with you.

ANSWER:

INTERROGATORY NO. 8: Identify all persons involved in the decision not to promote _____________.

ANSWER:

INTERROGATORY NO. 9: Please state the number of, and describe with particularity, all written or oral customer complaints concerning _____________.

ANSWER:

INTERROGATORY NO. 10: Please state the number of, and describe with particularity, all written or oral complaints made by your employees or co-workers concerning _____________.

ANSWER:

INTERROGATORY NO. 11: Which _____________ or entity do you contend employed Plaintiff?

ANSWER:

INTERROGATORY NO. 12: Did ____________ or ___________ employ or have any connection with the allegations complained of in Plaintiff’s Original Petition?

ANSWER:

DOCUMENTS TO BE PRODUCED

You are hereby requested to produce the following documents and tangible things as defined under the definitions section of this discovery request at the offices of your attorney for inspection and copying by...