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...