Plaintiff's "triple threat" discovery propounded to defendant in sexual harassment case

[Style of Case]

PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS,

FIRST SET OF INTERROGATORIES AND FIRST

REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT

TO: Defendant _____, by and through its counsel of record _____.

Pursuant to the [Federal/Texas] Rules of Civil Procedure, Plaintiff _____ (hereafter "Plaintiff") submits to you the following discovery.

[INSERT STANDARD INSTRUCTIONS & DEFINITIONS FOR A PLAINTIFF: 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

REQUEST FOR ADMISSIONS

[INSERT STANDARD REQUESTS FOR PRODUCTION: FORM DIS018]

[ADDITIONAL REQUESTS FOR PRODUCTION TAILORED SPECIFICALLY FOR A SEXUAL HARASSMENT CASE ARE LISTED BELOW.]

REQUEST NO. 1:Admit that _____ investigated the sexual harassment claim filed by _____ against _____.

RESPONSE :

REQUEST NO. 2:Admit that as a result of such investigation, _____ concluded that sexual harassment had taken place. If this Request for Admission is denied, then answer Interrogatory No. _____.

RESPONSE :

REQUEST NO. 3:Admit that _____ followed the sexual harassment policy of _____ in reporting said sexual harassment. If this Request for Admission is denied then answer Interrogatory No. 17.

RESPONSE :

REQUEST NO. 4:Admit that _____ complained to _____ that Plaintiff felt _____ was making sexual requests of Plaintiff.

RESPONSE :

REQUEST NO. 5:Admit that Defendant hired someone to replace Plaintiff.

RESPONSE :

REQUEST NO. 6:Admit that _____ was sent to work with Plaintiff as a possible replacement for Plaintiff.

RESPONSE :

REQUEST NO. 7:Admit that _____ was told that _____ was sent to work with Plaintiff as a possible replacement or otherwise knew of this purpose.

RESPONSE :

REQUEST NO. 8:Admit that Plaintiff had been a satisfactory employee while Plaintiff worked for you.

RESPONSE :

INTERROGATORIES

[INSERT STANDARD INTERROGATORIES FOR A PLAINTIFF: FORM DIS018]

[ADDITIONAL INTERROGATORIES TAILORED SPECIFICALLY FOR A SEXUAL HARASSMENT CASE ARE LISTED BELOW.]

INTERROGATORY NO. 1: Please identify all written or oral complaints made to you or your predecessor or successor corporations in the last 10 years to the present by any person, union, or other entity regarding sexual harassment and/or any unfair labor or employment practices.

ANSWER :

INTERROGATORY NO. 2: Please identify every written or oral complaint filed in the last 10 years to the present against you or your predecessor or successor corporations with the Federal Trade Commission, the EEOC, the Texas Commission on Human Rights, any state or federal Attorney General, the Texas Workforce Commission, the Texas Workers’ Compensation Commission, the Industrial Accident Board, the Better Business Bureau, any television, newspaper, radio, or other media entity, or consumer watchdog organizations regarding wrongful discharge, employment discrimination or any unfair labor or employment practices.

ANSWER :

INTERROGATORY NO. 3: Identify every lawsuit filed in the last 10 years to the present against you or your predecessor or successor corporations alleging any cause of action for sexual harassment, retaliation, wrongful discharge, or unfair labor or employment practices.

ANSWER :

INTERROGATORY NO. 4: Identify every settlement agreement that you have entered into in the last 10 years with any person, party, or entity where they alleged that you...