Free Interrogatories Propounded - District Court of Delaware - Delaware


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Case 1:05-cv-00015-SLR Document 20 Filed 07/27/2005 Page 1 of 13
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
STEPHANIE F. HAYGOOD )
Plaintiff, g
) C.A. N0. 05-00015-SLR
v. )
)
BARRY CONNORS, LINDA HARE-TUCKER, )
KEN KOON AND SHEILA FERRARO, )
Defendants. g
DEFENDANTS’ FIRST SET OF
INTERROGATORIES TO PLAINTIFF
Defendants herewith propounds, pursuant to the Federal Rules of Civil Procedure,
Interrogatories to be answered under oath by Plaintiff, Stephanie F. Haygood, within thirty days
of service hereof. These Interrogatories are to be deemed continuing.
I. INSTRUCTIONS AND DEFINITIONS
When in these Interrogatories you are asked to identify a person, identify him by name; if
his name is not known and he is an officer or employee of Defendants or any affiliated
corporations, identify him by job title and date when he held that job; if no other identification is
possible, provide a sufficient description so that he will be identifiable to the recipients of your
answer. State his current home address, current employer, and address of his current employer.
When in these Interrogatories you are asked to state the date on which some incident or
event occurred, provide the day, month and year if known; if day is not known, provide the
month or season along with the year; if month and/or year is not known, identify the date by
relating it to some established time (e. g., "six months after I was hired.")
"Documents" shall mean all written and printed matter of any kind in your possession,
custody or control which is either known to you or can be located or discovered by diligent
Docs_DE ll3500vl