Text of US Department of Justice's First Set of Interrogatories and Document Requests, served on Caryl Leventhal on February 17, 2000

CLAIMS OF PRIVILEGE

Pursuant to Local Civil Rule 26.2 of the Southern District of New York, if you refuse

to respond to any interrogatory or document request, or subpart thereof, on the ground of privilege, identify:

1.    the nature of the privilege, including work product;

2.    if the privilege is being asserted in connection with a claim or defense governed by state law, the state's privilege rule being invoked;

3.    with respect to each document:

a. the type of document,

                    b. general subject matter of the document, the date of the document,

                    c. the author(s) and addressees) of the document and the 

                    d. relationship of the author and the addressee(s) to each other, and

                                        e. any recipient of the document; and

    4.    with respect to each oral communication:

                    a. the name of the person making the communication,

                    b.  the names of all persons present while the communication was made,

                    c. the relationship of the person present to the person making the communication,

                    d. the date and place of the communication, and

                    e. the general subject matter of the communication.

INTERROGATORIES

1.    Identify each and every person or organization that has provided medical care or treatment to plaintiff for injuries, ailments or any problem plaintiff alleges to be related to her claims in this action.

2.    Identify each and every person, organization or other health_care professional plaintiff has consulted regarding injuries, ailments or any problem plaintiff alleges to be related to her claims in this action.

3.    Identify all persons with possession, custody or control of medical records concerning the treatment(s) and consultations) described in Interrogatories 1 and 2.

4.    Identify all persons with knowledge or information relevant to the claims in this action, including, but no limited to:

                a. all persons in the INS who have employed and/or supervised plaintiff during the time of the alleged discriminatory acts;

                b. all witnesses or other persons with knowledge or information regarding the events that are alleged to be discriminatory, specifying which witness or other person has knowledge or information regarding which event;

                c. all persons who have acted on plaintiffs behalf with respect to, or have investigated, the matters set forth in the complaint;

                d. any INS employee, agent or representative or any person purporting to act on behalf of the INS who has made any oral or written statement to anyone, including plaintiff, regarding the matters set forth in the complaint;

                e. all persons who have written any report or made any written statement in connection with any of the matters set forth in the complaint;

                f. all persons with possession, custody or control of any report or statement made by a person identified in response to Interrogatories 4(d) or 4(e);

 

    *The Government will seek to preclude the testimony of any individual not listed in response to this interrogatory.

            g. all agents, servants and/or employees of the INS who allegedly took part in the claimed discriminatory conduct, specifying which agents, servants and/or employees were involved in each alleged discriminatory act;

            h. all experts consulted by or on behalf of plaintiff in connection with the claims in this action; and

            i. any other individual not listed above with knowledge or information concerning the subject matter of this action.

5.    Identify each and every person or organization by whom plaintiff has been employed at any time on or after January 1, 1990.

6.    Identify each and every expert witness that plaintiff will call to testify at trial, and for each expert state:

            a. His or her field of specialty or expertise;

            b. Any sub-specialties of the witness within his or her field of expertise;

            c. The subject matter on which he or she is expected to testify;

            d. All opinions as which he or she is expected to express and the basis and reasons therefor;

            e. The data or other information he or she considered in forming his or her opinion(s);

            f. Any exhibits to be used as a summary of or support for his or her opinion(s);

            g. His or her qualifications, including a list of all publications that he or she authored within 10 years preceding the date of this request;

            h. The compensation paid and to be paid to him or her for the study and the testimony; and

            i. All other cases in which he or she has testified as an expert at trial or by deposition within four years preceding the date of this request.

7.    State the amount for each category of damages for which judgment is sought, including without limitation compensatory damages for economic losses, compensatory damages for emotional distress, the costs of this action and attorneys' fees.

8.    Set forth the computation used to arrive at each amount of damage set forth in response to Interrogatory 7.

9.    Identify each document supporting or concerning each amount of damage set forth in response to Interrogatory 7.

REQUEST FOR DOCUMENTS

You are hereby requested to produce the following documents:

1.    All reports or other written statements, written by or to the persons identified in response to Interrogatory 4 relating to the matters alleged in the complaint.

2.    All documents submitted to the INS in connection with the matters alleged in the complaint.

3.    All documents received from the INS in connection with the matters alleged in the complaint.

4.    All documents referred to in the complaint.

5.    All documents describing, relating or referring to the hiring and employment of plaintiff by the INS, including, but not limited to, qualification, salary, bonuses and all benefits that plaintiff was to receive, did receive, or is to receive by virtue of her employment with the INS.

6.    All documents describing, relating or referring to plaintiffs work for the INS, including, but not limited to, documents evidencing, referring or relating to plaintiffs qualifications, training, type of work performed and Work performance.

7.    All documents describing, relating or referring to any promotions, demotions, transfers, or increases or reductions in compensation that plaintiff was to receive, did receive, or is to receive by virtue of her employment with the INS.

8.    All documents describing, relating or referring to the INS's employment policies and/or procedures, including, but not limited to, employment or training manuals, memoranda received by plaintiff relating to job responsibilities and/or duties and other material concerning terms and conditions of employment.

9.    All documents concerning INS policies, procedures, practices, employees, former employees or activities in plaintiffs possession or control.

10.    All documents concerning plaintiffs termination from the INS.

11.    All documents describing, relating or referring to communications or statements made by any INS employee, agent and/or representative that referred or related to plaintiffs race, religion or disability.

12.    All documents describing, relating or referring to the alleged race discrimination described in the complaint.

13.    All documents describing, relating or referring to the alleged religious discrimination described in of the complaint.

14.    All documents describing, relating or referring to the alleged discrimination based on plaintiffs disability described in the complaint.

15.    All documents describing, relating or referring to the alleged damages caused to plaintiff by the claimed conduct of the INS.

16.    All documents written or authored by plaintiff or by any other person evidencing, referring to or relating to the matters alleged in the complaint, including, but not limited to, all personal diaries, calendars, notebooks, appointment books, phone messages, memoranda, and weekly or daily planners of the plaintiff.

17.    All documents written by or to any person who has investigated or reported on the matters alleged in the complaint on plaintiffs behalf

18.    Each and every federal or state income tax return filed by plaintiff for the years 1995 to the present.

19.    All documents supporting or concerning any claim for lost wages, including, but not limited to, employment agreements for 1995 through the present, bank statements from 1997 through the present, tax documents (eg., W-2 forms, 1099 forms) for 1995 through the present, and any other document reflecting income earned or received by plaintiff for 1995 through the present.

20.    All records regarding plaintiff in the possession of any person or organization named in response to Interrogatories 1, 2 and 3 above.

21.    Notarized authorizations from plaintiff permitting the documents set forth in Request 20 to be produced to counsel for the defendant.

22.    For each expert named in response to Interrogatory G above:

    a. A curriculum vitae, including qualifications and a list of all publications authored by the witness within the preceding 10 years;

    b.All documents considered by the expert in connection with his or her services in this matter;

    c. All documents supplied to the expert by plaintiff; and

    d. Any report and accompanying exhibits produced by the expert in connection with his or her services in this matter.