123.

Sample Interrogatories

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA, Plaintiff, v. CIVIL ACTION NO. 93C 1794 JUDGE GRADY GHEORGHI NEDIALKOV (also known MAGISTRATE JUDGE LEFKOW as GEORGE NEDIALKOV), and JAMES NEDIALKOV, Defendants. _________________________________ PLAINTIFF'S SECOND SET OF INTERROGATORIES TO DEFENDANT GHEORGHI NEDIALKOV To: Defendant Gheorghi Nedialkov c/o Gregory J. Schlesinger, Esq. 180 N. La Salle Street Chicago, Illinois 60601 Plaintiff requests that the defendant answer each of the following Interrogatories separately and fully, in writing and under oath in accordance with Rule 33 of the Federal Rules of Civil Procedure. INSTRUCTIONS If the information requested by any Interrogatory is contained in documents, papers or records in the custody of defendant, you may so indicate and answer that Interrogatory by attaching copies of such documents or papers to your answers and by indicating the Interrogatory to which those documents or papers are deemed responsive. These Interrogatories call for all information available to the defendant, his employees, and agents with respect to the subject matter into which they inquire. If some of the information is known by or available to a particular employee or agent, please include in your answers all information known by or available to each employee or agent. Please identify which employee or agent provided information with respect to each answer. Where a claim of privilege or attorney work product is asserted in objecting to any interrogatory, or subpart thereof, identify the privilege dalimed, and if the privilege is governed by state law, indicate the state privilege rule being invoked. If an objection goes to the production of a document, identify in writing each document so withheld by providing at least the following information: the title, date and the subject matter of this document; the title and the position of the sender of the document; the identity and position of each person who participated in the preparation of the document or on whose behalf the document was prepared; the identity and position of all persons (1) to whom the document was addressed, (2) to whom the document was sent, (3) who have seen the document, (4) who have possession or custody of the document, or (5) who have had disclosed to them any of the contents of the documents; a detailed statement of the basis for withholding the document, including facts establishing any claim of privilege, facts showing that the privilege had not been waived and the status of the person claiming the privilege, and Identify and produce each segregable portion of any document to which the claim of privilege, attorney work product or other basis for withholding the document does not apply. If the claim of privilege or work product goes to an oral communication, please provide the following information: the name of the person making the communication and the names of the persons present when the communication was made, the date and the place of the communication, the general subject matter of the communication, and a detailed statement of the basis for withholding the document, including facts establishing any claim of privilege, facts showing that the privilege has not been waived and the status of the person claiming the privilege. DEFINITIONS As used in these interrogatories: "Identify," "identification," and "identity" mean: when used in reference to a natural person they mean to state the person's full name, current residence and business addresses, current residence and business telephone numbers and, if applicable, his or her title, dates of employment, and job description. If current addresses are unknown, provide the last known business and residence address; when used in reference to a business entity they mean to state the structure of the business (i.e., corporation, partnership (limited or general), sole proprietorship), the business address and telephone number, and if licensed, the description of those licenses, including identifying the issuing authority; when used in reference to a document they mean to state the type of document (e.g., letter, memorandum, telegram, chart, etc.), its author and originator, its date or dates, all addressees and recipients, and its present location or custodian. If any such document was but is no longer in your possession or subject to your control, state what disposition was made of it, including the date that it left your possession or control and identify the person to whom you transferred it. INTERROGATORIES For any residential property you own or have ever owned, identify any and all persons and/or companies who provided services with respect to showing, renting, maintaining or advertising of such property, at any time, stating their name, date of birth, social security number, last know address and telephone number, and the dates of such service. Identify all businesses related to the purchase, sale and/or rental of residential real estate property, in which you have had an ownership interest, at any time, during the period January 1, 1978 to the present, by stating the name, address and legal form under which the business was or is conducted (e.g. sole proprietor, partnership, etc.). Identify all persons who you or your attorney have contacted, or from whom you or your attorney have either obtained or requested a statement, regarding the allegations of the complaint of the United States in this action by stating their name, address, last known work and home telephone numbers, their sex and race. Identify any complaints or charges of sexual harassment, sexual battery or sexual assault, either of a civil or criminal nature, which have been made against you or any employee of yours; include the name and address of the complainant, the date of each complaint or charge, the case or docket number , and its final disposition (or current status if still pending). State your defenses to this lawsuit and all facts that support or may tend to support each of the defenses. Identify all persons who have knowledge of facts which support or may tend to support your defense(s) and provide a summary of the facts or information in each such person's possession which supports or may tend to support your defense(s). Identify any female who has ever been a tenant at any rental property owned or managed by you with whom you have ever engaged in sexual relations, including touching of a sexual nature, kissing or sexual intercourse, either during or before or after her tenancy. For each person identified, include the name of the tenant, address of the rental property, date(s) of tenancy, and state whether the sexual relations occurred before, during or after the period of tenancy. Identify all persons who participated in answering these interrogatories. Provide dates of birth, social security number and any other information you have about Raymond Medina, George Luiggi, Cordell Morgan. ______________________________ Isabelle M. Thabault Barbara Kammerman Valerie O'Brian Attorneys Housing and Civil Enforcement Section Civil Rights Division U.S. Department of Justice P.O. Box 65998 Washington, D.C. 20035-5998 (202) 514-1006 CERTIFICATE OF SERVICE I hereby certify that on the ____ day of May, 1993, I mailed a copy of the foregoing Plaintiff's Second Set of Interrogatories to counsel for defendants, Gregory J. Schlesinger, 180 N. LaSalle Street, Suite 1708, Chicago, Illinois 60601 and Judith A. Scully, 343 S. Dearborn, Suite 605, Chicago, Illinois 60601. ________________________ Barbara Kammerman Attorney U.S. Department of Justice Washington, D.C. [cited in Civil Rights Resource Manual 60]