Caryl Requests

THE UNANSWERED QUESTIONS: Why will judge Shira Scheindlin keep from the jury and court record, evidence and testimony of the rampant terrorist friendly corruption Caryl Leventhal was attempting to stop (You can find it by going to the Sworn Deposition of Brenda Grant). Why will Eric B. Fisher, Deputy US Attorney place winning a case over information from this whistleblower that could warn the American people of terrorism? Why will Alan R. Kaufman, Chief of the US Attorney's (Southern District) Criminal Division threaten The Leventhal family with arrest and prosecution if they didn't censor this website to place the US Department of Justice in a better light? Why are they working to place America at risk?

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

--------------------------------------------X 99 Civ. 10405 (SAS)

CARYL B. LEVENTHAL,

PLAINTIFF=S FIRST INTERROGATORIES

Plaintiff,

-against-

HON. JANET RENO, ATTORNEY

GENERAL OF THE UNITED STATES,

Defendant.

---------------------------------------------X

To: Eric B. Fisher, Esq.

Assistant United States Attorney

Attorneys for Defendant

100 Church Street, 19^th Floor

New York, NY 10007

PLEASE TAKE NOTICE that plaintiff, by her attorney, MICHAEL R. BRESSLER, ESQ., hereby requests, pursuant to FRCP Rule 33 that defendant responds to the following interrogatories by March 14, 2000.

INSTRUCTIONS AND DEFINITIONS

1. APerson@ is defined as any natural person or any business, legal or governmental entity or association.

2. AIdentify@ means, when referring to a person, means to give, to the extent known, the person=s full name, his/her present resident and/or business address and telephone number, and if that is not known, the answer shall so state; in lieu of his/her present residence and/or business address, the answer shall so state his/her last known residence and/or business address and the last known date when he/she resided there.

When referring to documents, Ato identify@ means to give, to the extent known: (i) the title, heading or caption of such document, if any; (ii) the identifying number(s), letter(s), or any combination thereof, if any, and the significance or meaning of such; (iii) type of document; (iv) general subject matter; (v) date of the document; (vi) author(s), address(es), and recipient(s).

3. ADocument@ is defined to be synonymous in meaning and equal in scope to the usage of this term in FRCP Rule 34(a). A draft or nonidentical copy is a separate document within the meaning of this term.

4. AParties@ means the plaintiff or defendant as well as a party=s full or abbreviated name or pronoun referring to a party mean the party and/ where applicable, its officers, directors, employees, or agents. This definition is not intended to impose a discovery obligation on any person who is not a party to the litigation.

5. AConcerning@ means relating to, referring to, describing, evidencing, or constituting.

6. Should defendant claim privilege for any documents about which information or inspection is requested by any of the following interrogatories, such documents shall be described in a manner sufficient for identification including the date, author, recipient, and identity of each party receiving a copy of the document and the subject matter thereof, and in addition to supplying the above-named information concerning such documents, shall indicate that plaintiff claims privilege therefore and plaintiff shall state the ground on which the claim of privilege rests.

7. All interrogatories herein are continuing in nature, so as to require defendant to supplement or amend her responses in accordance with FRCP Rule 26(e).

INTERROGATORIES

1. Identify the person answering these interrogatories.

2. Identify all persons with knowledge or information relevant to the subject matter of this action.

3. Identify any and all persons which plaintiff intends to call as experts at trial, and specify the subject matter upon which each expert is expected to testify, giving a statement regarding the substance of the facts and opinions to which the expert is expect to testify at trial and a summary of the grounds for each opinion.

4. Concerning the clerical work force in the United States Immigration and Naturalization Service (AINS@), New York Office, Section 245 (A245"), between the years 1994 and 2000, set forth, for each year: (i) how many clerical staff were budgeted to work, per year, in the section; (ii) how many clerical staff actually worked, per year; (iii) how many of said staff, per year, were African American; Asian; Hispanic; or non-Hispanic whites; (iv) how many of said staff, per year, were Christian (of any denomination); Jewish; Muslim; or other; and (v) how many suffered from a disability of any kind and identify the disability; (vi) for each set forth position and length of time in position; (vii) if no longer in position provide employment status and transfer position.

5. Identify all persons who filled the position of ASupervisory Applications Clerk@ in 245 between 1975 and 2000, including: (i) race; (ii) religion; (iii) time period holding that position; (iv) date(s) marked AAWOL@.

6. Between 1990 and 2000, identify the number of employees in 245 were given leave for religious holidays, including but not exclusive to: Good Friday, Yom Kippur, Black Solidarity Day, Kwanza? List holiday and duration.

7. Between 1990 and 2000, were any employee(s) in 245 arrested for any crime. If so, identify the (i) the race and religion of the arrested person; (ii) the offense he or she was arrested for; (iii) the date of the arrest; (iv) action, if any, taken by the INS in response.

8. Between 1990 and 2000, identify all persons, other than plaintiff, who were terminated from 245. Of those identified, provide: (i) race; (ii) religion; (iii) if they suffered from a disability and if so, identify; (iv) were they critically ill at the time of their termination; (v) date of termination; (vi) the individual who made the termination decision; and (vii) reason for the termination.

9. Between 1990 and 2000, identify all persons at 245, other than plaintiff, who were marked AAWOL.@ Of those identified, provide: (i) race; (ii) religion; (iii) if they suffered from a disability and if so, identify; (iv) dates they were marked AWOL; (vi) the reason they were marked AWOL.

10. Between 1990 and 2000, identify all employees at 245, other than plaintiff, who were denied a day or day(s) off to observe religious holidays. Include: (i) reason for denial; (ii) person who denied holiday; (iii) employee=s race and religion; (iv) date of holidays.

11. Identify all persons who recommended that plaintiff=s employment be terminated.

12. Identify all persons who participated in the decision that plaintiff=s employment be terminated

13. Identify all communications relating to the decision to terminate plaintiff=s employment.

14. Identify all days plaintiff was marked AAWOL@ from her employment and the reason for such marking.

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

--------------------------------------------X 99 Civ. 10405 (SAS)

CARYL B. LEVENTHAL,

PLAINTIFF=S FIRST REQUEST FOR PRODUCTION

Plaintiff,

-against-

HON. JANET RENO, ATTORNEY

GENERAL OF THE UNITED STATES,

Defendant.

---------------------------------------------X

PLEASE TAKE NOTICE that plaintiff, by her attorney, MICHAEL R. BRESSLER, ESQ., hereby requests, pursuant to FRCP Rule 29, 33, and 34 that defendants produce for inspection and copying the following documents within the time and in the manner specified by these rules. The documents shall be produced at the offices of Michael R. Bressler, Esq., 36 West 44^th Street, Suite 1100, New York, NY 10036 on March 14, 2000 at 10:00 am or at such other date and time as counsel may agree.

INSTRUCTIONS AND DEFINITIONS

1. APerson@ is defined as any natural person or any business, legal or governmental entity or association.

5. AConcerning@ means relating to, referring to, describing, evidencing, or constituting.

7. All requests herein are continuing in nature, so as to require defendant to supplement or amend her responses in accordance with FRCP Rule 26(e).

REQUESTS FOR PRODUCTION OF DOCUMENTS

1. Please produce all documents you were requested to identify in plaintiff=s first interrogatories in this action or relating to or otherwise supporting your response to any interrogatory.

2. Please produce all documents relating to any evaluation (formal or informal) of plaintiff.

3. Please produce plaintiff=s personnel file and copies of any documents maintained in any file referencing plaintiff with respect to her health, performance, compensation, or any complaints made by or concerning plaintiff.

4. Please produce all documents relating to any written or oral reprimand, warning, or caution, or any compliment, award, or commendation, given to or concerning plaintiff.

5. Please produce copies of all communications between plaintiff and defendants, or relating to plaintiff, by or to any employee of defendants, or relating to plaintiff, by or to any employee of the United States Immigration and Naturalization Service (AINS@), New York Office, Section 245 (A245") or otherwise employed by INS, of or relating to plaintiff by or to any outside person.

6. Please produce copies of all documents prepared by, or at the direction of, any employee of INS relating to plaintiff.

7. Please produce all documents relating to any contention by INS that plaintiff=s performance was unsatisfactory.

8. Please produce all documents relating to the job descriptions for the position held by plaintiff.

9. Please produce all documents relating to or supporting your denial of any allegation of plaintiff=s complaint, and relating to or supporting each affirmative or general defense asserted by defendants.

10. Please produce all documents relating to plaintiff=s damages, including any documents supporting any contention that plaintiff is not entitled to all or part of the damages claimed (this request relates specifically to damages, not to the merits of the underlying claims).

11. Please produce copies of all documents relating to the charges filed by plaintiff to the Equal Employment Opportunity Commission or any other federal administrative agency.

12. Please produce all documents relating to or referring to plaintiff=s inadequate job performance.

13. Please produce all documents relating to or referring to all steps taken to investigate plaintiff=s complaints of discrimination.

14. Please produce all documents relating in any manner to plaintiff, without date limitation.

15. Please produce complete copies of all documents signed by plaintiff while employed by INS.

16. Please produce all documents relating to the decision to terminate plaintiff=s employment.

17. Please produce copies of any employee handbook or personnel manual disseminated by INS, while plaintiff was employed.