Free Motion to Compel - District Court of Delaware - Delaware

Case 1A:O4-cv-01469-SLR Document 36-2 Filed 08/O3/2OCl6 Paget of4 . A
E — IN THE UNITED STATES DISTRICT COURT . UA as I
FOR THE DISTRICT OF DELAWARE · - A » A
STANFORD L; BIJRRIS, I A ‘ V) I _ I A A
A Plaintiff, I g . A U · -
v. A U A V C.A. N0.: 04-1469 (SLR) _‘ _ I
i RICPLARDS PAVING, INC. V ‘ A _ A
Defendant. · I A g l I U
I PLAINTIF F 'S SECOND SET OF IN TERROGATORIES A A
AA ‘ » DIRECTED TO DEFENDANT _.·» ‘ · A
I A General Objections _ V `
‘ l. Richards Paving, Inc., (hereinafter referred to as "Richards Paving"), objects A » _ _
to Plaintiffis Discovery on the grounds that it is overly broad, unduly burdensome, seeks _
information which is not relevant to Plaintiff’s cause of action, and seeks information ‘
which is not reasonably calculated to lead to theA discovery of admissible evidence. .
Without waiving this objection, and subject to any additional objections herein, Richards
Paving provides its Answers herein. · A A A ‘ - ‘ H A
iiii K _ 2. Richards Paving objects to Plaintiff’s Discovery to the extent that said .
Discovery seeks information protected by either the attorney-client privilege or the work
. —product doctrine. Without waiving this objection, and subject to any additional _ U A
objectionsherein, Richards Paving provides its Answers herein. A A _ A
3. A Richards Paving objects to Plaintiff’s Discovery to-the extent that it seeks ~
l information that is-not within the custody or control of Richards Paving, is otheiwise A h A -
public domain, or is otherwise equally or more available to Plaintiff than to Richards .
Paving. Without waiving this objection, and subject to any additional objections herein,

I Clase1:O4-cv—O1469-SLR Document 36-2 A lFi|ed 08/O3/2006 Page 2 of 4
if Richards Paving provides its Answers herein. · ' ‘ l U A [
__ A · 4. Richards Paving objects to Plaintiff’s Discovery to the extent that it asserts
l ¤ and/or assumes unproven conclusions as established facts. Without- waiving this - M
‘ objection, and subject to any additional objections herein, Richards Paving provides its A .
’ ·• Answers herein; l ‘ . ‘ - ·» R
1 ( 4 _ 5. Richards Paving objects to Plaintiff’s Discovery to the extent that it A ‘
_ assumes, the truth of the allegations which are in dispute in this litigation and/or makes A
A P l incorrect and/or untrue assertions, and/or assumes unproven. conclusions as established, V
l A _ facts. Without waiving this objection, and subject-to any additional objections herein, »
U Richards Paving provides its Answers herein. A » l _ V , A
Q _ 6. Richards Paving objects to Plaintiff’-s Discovery to the extent that it seeks V _
to require it to provide information other than that which may be obtained through a ‘ V
U A reasonably diligent search of its records. A V it l
V — .7.. The responses made herein are made without in any way waiving or _ ‘
· · intending to waive, but on the contrary intending to reserve and reserving: (l) the right to A I _
‘ object onthe grounds of competency, privilege, relevancy, and materiality, or any other R
· V proper ground, to the use of such information, for any purpose, in whole or in part, in at
subsequent step or proceeding in this action or any other action; (2) the right to object and
any and all grounds at any time, to any other discovery procedure involving or relating to
A U the subject matter of Plaintiff’s Discovery; and (3) the right to supplement these answers
should additionalinformation be discoveredp c V
1 Notwithstanding and without waiving these objections,Richards Paving hereby l
responds to Plaintiffts Discovery as follows: - V

` l Case1:O4-cv¥O1469¥SLFl Document 36-2 A Filed 08/O3/2006 Page 3 of4
1. List by year, for the years 2003, 2004, 2005, and 2006 each and every person ‘ I
. V employed by the defendant as a truck driver, stating their names, addresses, and dates of
s if birth, and, please state the date of hire for each such individual, and if that individual is l . if
. T no longer employed by the defendant the date of his/her termination and reason for _
U lt termination. ‘ V . · I _ if .1 l {
` = ANSWER 1 t r ° t
‘ Richards Paving objects to this Interrogatory as overly broad, burdensome, and -
( ‘ T harassing. This interrogatory is neither relevant nor designed to lead to discoverablel ‘ _
_ t V T information. . _ ‘ ‘
V l 2. V. For each person listed in the answer Interrogatory N o. V1, please statetheir hourly ·
_ V P wage for each year that they were employed by the defendant ..h° s _
_ ANSVVER ` i _ » s »
Richards Paving objects to this Interrogatory as overly broad, burdensome, and ~_ A
l 1 s harassing. This interrogatory is neither relevant nor designed to lead to discoverablé `
l irqo rmation. , ·V , yl U
3. For each person listed in the answer to Interrogatory No. 1, please list the nuniber 1
· of hours worked foreach year for that individual. T
ANSWERT T ‘ _
Richards Paving objects to this Interrogatory as overly broad, burdensome, and e
harassing. This interrogatory is neither relevant nor designed to lead to discoverable
i1y'ormation. » 1 V _ A V

9 Case 1 :04-cv-01469-SLR Doeument 36-2 Fi|ed‘O8/O3/2006 Page 4 of 4 A
ELZUFON AUSTIN REARDON V A
As to Obejctions: “ TARLOV & MONDELL, P.A. , »
3 A MATTHEW P. DONELSON (ID #4243)
V 300 Delaware. Avenue, 17th Floor
1 P. O. Box 1630 ) _
V Wilmington, DE 19899-1630 . —
' (302) 428-3181 .»
‘ Attorney for Defendant
J 3 A Dated: Q Q 2 ( [ OC ~ ‘