UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CIVIL DIVISION

CASE NO.: ______________________

_________________________________________ x NELLY HARRISON.

Plaintiff,
v.

HUNTER BECK d/b/a/ BECK INTERNATIONAL Defendants.
_________________________________________x

PLAINTIFFS FIRST SET OF RULE 26.1(g) INTERROGATORIES TO DEFENDANTS

Nelly Harrison propounds the following interrogatories upon Hunter Beck Operating As Beck International and requests that they be answered separately, fully and under oath within thirty (30) days of service pursuant to Federal Rule of Civil Procedure 33 and Local Rule 26.1(g).

DEFINITIONS

(a) The words “you,” “yours” and/or “yourselves” means Beck International and any directors, officers, employees, agents, representatives or other persons acting, or purporting to act, on behalf of Beck International.
(b) The singular shall include the plural and vice versa; the terms “and” or “or” shall be both conjunctive and disjunctive; and the term “including” mean “including without limitation”.
(c) “Date” shall mean the exact date, month and year, if ascertainable or, if not, the best approximation of the date (based upon relationship with other events).
(d) The word “document” shall mean any writing, recording, electronically stored information or photograph in your actual or constructive possession, custody, care or control, which pertain directly or indirectly, in whole or in part, either to any of the subjects listed below or to any other matter relevant to the issues in this action, or which are themselves listed below as specific documents, including, but not limited to: correspondence, memoranda, notes, messages, diaries, minutes, books, reports, charts, ledgers, invoices, computer printouts, microfilms, video tapes or tape recordings.
(e) “Agent” shall mean: any agent, employee, officer, director, attorney, independent contractor or any other person acting at the direction of or on behalf of another.
(f) “Person” shall mean any individual, corporation, proprietorship, partnership, trust, association or any other entity.
(g) The words “pertain to” or “pertaining to” mean: relates to, refers to, contains, concerns, describes, embodies, mentions, constitutes, constituting, supports, corroborates, demonstrates, proves, evidences, shows, refutes, disputes, rebuts, controverts or contradicts.
(h) The term “third party” or “third parties” refers to individuals or entities that are not a party to this action.
(i) The term “action” shall mean the case entitled Harrison v. Beck International pending in the Unites States District Court for the Southern District of Florida.
(j) The word “identify”, when used in reference to a document (including electronically stored information), means and includes the name and address of the custodian of the document, the location of the document, and a general description of the document, including (1) the type of document (e.g., letter or memorandum) and, if electronically stored information, the software application used to create it (e.g., MS Word or MS Excel Spreadsheet); (2) the general subject matter of the document or electronically stored information; (3) the date of the document or electronically stored information; (4) the author of the document or electronically stored information; (5) the addressee of the document or electronically stored information; and (6) the relationship of the author and addressee to each other.

INSTRUCTIONS

If you object to fully identifying a document, electronically stored information or oral communication because of a privilege, you must nevertheless provide the following information pursuant to Local Rule 26.1(g)(3)(B)(ii), unless divulging the information would disclose the privileged information:
(1) the nature of the privilege claimed (including work product);
(2) if the privilege is being asserted in connection with a claim or defense governed by state law, the state privilege rule being invoked;
(3) the date of the document, electronically stored information or oral communication;
(4) if a document: its type (e.g., letter or memorandum) and, if electronically stored information, the software application used to create it (e.g., MS Word or MS Excel Spreadsheet), and the custodian, location, and such other information sufficient to identify the material for a subpoena duces tecum or a production request, including where appropriate the author, the addressee, and, if not apparent, the relationship between the author and addressee;
(5) if an oral communication: the place where it was made, the names of the persons present while it was made, and, if not apparent, the relationship of the persons present to the declarant; and
(6) the general subject matter of the document, electronically stored information or oral communication.
You are under a continuous obligation to supplement your answers to these interrogatories under the circumstances specified in Federal Rule of Civil Procedure 26(e).

INTERROGATORIES

1. Please provide the name, address, telephone number, place of employment and job title of any person who has, claims to have or whom you believe may have knowledge or information pertaining to any fact alleged in the pleadings (as defined in Federal Rule of Civil Procedure 7(a)) filed in this action, or any fact underlying the subject matter of this action.
2. Please state the specific nature and substance of the knowledge that you believe the person(s) identified in your response to interrogatory no. 1 may have.
3. Please provide the name of each person whom you may use as an expert witness at trial.
4. Please state in detail the substance of the opinions to be provided by each person whom you may use as an expert witness at trial.
5. Please state each item of damage that you claim, whether as an affirmative claim or as a setoff, and include in your answer: the count or defense to which the item of damages relates; the category into which each item of damages falls, i.e. general damages, special or consequential damages (such as lost profits), interest, and any other relevant categories; the factual basis for each item of damages; and an explanation of how you computed each item of damages, including any mathematical formula used.
6. Please state the names and years of employment for all employees who arrived late with Beck International within the last five (5) years.
7. Please provide the names of each person who took the test, as well as their years of employment with the company and all qualifications.
8. Please indentify the sex, race, age and rate of pay for the person who replaced the Plaintiff.
9. Until the date when the plaintiff stopped working for you, state whether there was every any complaint relative to the plaintiff’s ability to do the work assigned, and, if so, describe this in detail.
10. Describe in detail each reason why the plaintiff’s employment was terminated with the defendant employer. CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served by first class mail, postage prepaid 31 of January 2014, upon:

Respectfully submitted,

Kendrick & Branson, P.A. Attorneys for Plaintiff 53 Redwin Street Southside, FL 33233 Phone: 305-555-5555

By:________________________ Kaitlin Stapleton, Associate Florida Bar No. 1333433

By:________________________ Alex Taroff, Associate Florida Bar No. 11232221

Kaitlin Stapleton & Alex Taroff
Legal Writing and Research- Section 3c
Professor Chan
Semester Project 1 – Interrogatories
February 3, 2014