Free Statement - District Court of Colorado - Colorado

Case 1:03-cv-02435-PSF-PAC

Document 249-3

Filed 09/06/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
Civil Action No. 03-CV-02435-PSF-PAC (Consolidated with 04-CV-00639-PSF-PAC) LILLIAN F. SANDLE, Plaintiff,

ANTHONY J. PRINCIPI, Secretary, Department of Veterans Affairs, Defendant.

Civil Action No. 04-F-0639 (PAC) (Consolidated with 03-F-2435 (PAC)) LILLIAN F. SANDLE, Plaintiff,

ANTHONY J. PRINCIPI, ED SANCHEZ, RAYMOND DELUNA, and E. THORSLAND, JR., Defendants.

PLAINTIFF'S RESPONSES TO DEFENDANTS' SECOND SET OF REQUESTS FOR ADMISSIONS AND THIRD SUPPLEMENTAL SET OF INTERROGATORIES

Case 1:03-cv-02435-PSF-PAC

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privileges.

SECOND SET OF REQUESTS FOR ADMISSIONS
REQUEST NO. 36. Admit that your claims in this case are limited to those specifically contained in your formal administrative EEO complaints, which have been identified as administrative case numbers 89-0440,89-0441,93-1785,93-1790,93-1821 and 94-0858. RESPONSE: Denied. REQUEST NO. 37. Admit that, in your response to Interrogatory No. 2, contained within Plaintiffs First Supplemental Responses to Defendants' First Supplemental Set of Discovery Requests, dated January 27,2006, you have identified "each particular act by defendant [or defendants] suffered by you in violation of the Rehabilitation Act which is at issue in this case." RESPONSE: Denied. REQUEST NO. 38. Admit that you received $50,000.00 in settlement of the issues in this case pursuant to a written Settlement Agreement signed by you on April 2, 1997. RESPONSE: Admitted. REQUEST NO. 39. Admit that you have not returned the $50,000.00 to the Department of Veterans Affairs, the United States of America, or any federal official or federal office. RESPONSE: Admitted. REQUEST NO. 40. Admit that attorney fees of $16,600.00 was paid to your attorney at the time, in settlement of the issues in this case, pursuant to a written Settlement Agreement signed by you on April 2, 1997. RESPONSE: Denied. REQUEST NO. 41. Admit that you have not returned the attorney fees of $16,600.00 to the Department of Veterans Affairs, the United States of America, or any federal official or federal office. RESPONSE: Denied. REQUEST NO. 42. Admit that in June 1991 you were capable of driving an automobile. RESPONSE: Admitted. REQUEST NO. 43. Admit that in June 1991 you were capable of feeding yourself.

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this matter sets of limit of 40 interrogatories. Defendants have exceeded that limit. See. e.g;., Safeco of Am. v. Rawstron, 181 F.R.D. 441 (C.D. Cal. 1998); Stitching Mayflower Mountain Fonds v. The City of Park City Utah, No. 2:04CV925DAK, 2006 WL 1044446 (D. Utah April 14, 2006). Respectfully submitted this 3othday of June, 2006. HOGAN & HARTSON L.L.P.

~ e & Gallagher R. Elizabeth K. Pietsch Dugan W. Bliss 1200 Seventeenth Street, Suite 1500 Denver, CO 80202 Telephone: (303) 899-7300 Fax: (303) 899-7333 E-mail: sr~alla~her@,hhlaw.com ekpietsch@,hhlaw.com [email protected] Attorneys for Plaintiff Lillian F. Sandle

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CERTIFICATE OF SERVICE I hereby certify that on this 3othday of June, 2006, a true and correct copy of the foregoing PLAINTIFF'S RESPONSES TO DEFENDANTS' SECOND SET OF REQUESTS FOR ADMISSIONS AND THIRD SUPPLEMENTAL SET OF INTERROGATORIES was hand delivered to the following:
Michael Conrad Johnson U.S. Attorney's Office 1225 171hStreet, Suite 700 Denver, Colorado 80202 Michael.iohnson2~usdoi .gov

Case 1:03-cv-02435-PSF-PAC

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VERIFICATION The undersigned states that she has reviewed the foregoing PLAINTIFF'S RESPONSES TO DEFENDANTS' SECOND SET OF REQUESTS FOR ADMISSIONS AND THIRD SUPPLEMENTAL SET OF INTERROGATORIES, and verifies that the responses are true and correct to the best of the undersigned's knowledge, information, and belief.

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