Sample Interrogatories and Requests For yield in a Discrimination Lawsuit

Federal Workers Comp Lawyers - Sample Interrogatories and Requests For yield in a Discrimination Lawsuit

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(1) Please furnish a copy of the narrative of the victim. If any documents composing a portion of this data have already been produced, please recognize such documents.

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(2) Has the complaining witness, or any other person ever requested a copy of his/her narrative relating to employment with you? If the reply is ''yes,'' please state:

(a) Date upon which request was received;

(b) whether a copy of the file was provided, and if so, the date of production, the manner in which the copy was provided, and identification of documents provided;

(c) whether any material was added to the file following receipt of Plaintiff's request; and

(d) whether any material was deleted from her data following receipt of our request.

(3) Do you admit that you received a letter requesting our client's personnel narrative on or about [date]? If your reply is no, please state when you first received a written request for personnel record.

(4) Do you admit that on 2030, John Doe, provided a copy of our client's file to you?

(5) Are any documents included in our client's narrative that were not produced by you.

(6) Did any of her supervisors or any other employee of yours keep an ''unofficial'' file on our client, along with documents that are not contained in the official personnel record? If your reply is ''yes,'' please recognize who kept such a file and furnish copies of documents contained in each such ''unofficial'' personnel file.

(7) Do you have any documents relating to the hiring of our client? If your reply is ''yes,'' please furnish copies of all such documents.

(8) Was an exit interview conducted with our client? If your reply is ''yes,'' please recognize who conducted the interview.

(9) Were any documents generated that divulge to any exit interview or other conversation with Jane Doe after her termination of employment was announced? If your reply is ''yes,'' please furnish copies of all such documents.

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