Free Motion to Strike - District Court of Arizona - Arizona

ATFACI-IMENT D
Case 2:O3—cv—O2300-ROS Document 79-4 FiIed°O2/O9/2006 Pag@10f4

1 PAUL K. CHARLTON
United States Attorney
2 District of Arizona
3 JOHN R. MAYFIELD
Assistant U.S. Attorney
4 Arizona State Bar No. 4848
Two Renaissance Square
5 40 North Central Avenue, Suite 1200
Phoenix, Arizona 85004-4408
6 Telephone: (602) 514-7500
7 UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
8
9
Martha Slaughter—Payrre,
10 CIV-03-2300-PHX—ROS
1 1
DEFENDANT’S FIRST REQUEST
12 v. FOR ADMISSIONS; Second SET OF
13 INTERROGATORIES; Second
Anthony Principi, Secretary, Department of REQUEST FOR PRODUCTION
14 Veterans Affairs,
15
Defendant.
16
17 TO: Martha Slaughter-Payne and her attomey:
13 Under authority of Fed. R. Civ. P. 33, 34 and 36 defendant, United States of America,
19 hereby requests that the plaintiff answer in writing and under oath, within thirty (30) days from
the receipt hereof by hand delivery, the following requests for admission, interrogatories and
20 request for production. Pursuant to Rule 33.1 of the Local Rules of Practice for the District of
21 Arizona, the original completed set of responses to the requests for admission, interrogatories,
22 and request for production should be retumed to the United States Attomey for the District of
23 Arizona at the address shown above.
INSTRUCTIONS FOR USE IN AN SWERING INTERROGATORIES
24 1. All information is to be divulged which is in the possession, custody or control of each
25 individual or corporate party, their attomeys, investigators, agents, employees or other
26 representatives, including all information reasonably available to them.
2. Where an individual interrogatory calls for an answer which involves more than one
27
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_ ATTACHMENT D
Case 2:O3—cv—O2300-ROS Document 79-4 Filed O2/O9/2006 Page 2 of 4

1 defendant through the discovery process in this lawsuit.
2 21. Identify all VA documents regarding any allegation set forth in the Amended
3 Complaint and/or the joint Case Management Plan that you intend to, will or may rely
upon to support any allegation in the Amended Complaint and/or the Joint Case
4 Management that have not been produced by the defendant through the discovery
5 process in this lawsuit and that you intend to, will or may rely upon or proffer at the time
of trial, publish to the jury or seek to admit into evidence.
6
22. Identify any and all employment positions at the CTHVAMC that you claim you
7 were qualified for and which were vacant between September 1, 2001 and December 31,
2001.
8 Re uest for Production of Documents
q
9
7. Produce all documents responsive to Interrogatory # 18(above)that the plaintiff has in
10 her possession now or in the future should additional documents become available to her,
which have not been produced by the defendant through the discovery process in this
ll lawsuit and which you intend to, will or may rely upon, for any purpose, at the time of
12 trral.
13 8. Produce all documents responsive to Interrogatory #20 (above) that the plaintiff has in
her possession now or in the future should additional documents become available to her,
14 which have not been produced by the defendant through the discovery process in this
15 lawsuit, and which she intends to, will or may rely upon, for any purpose, at the time of
trial.
16
9. Produce all documents responsive to Interrogatory #21(above) that the plaintiff has in
17 her possession now or in the future, which have not been produced by the defendant
18 through the discovery process in this lawsuit, and she intends to, will or may rely upon,
for any purpose, at the time of trial.
19
10. Produce a complete set of any and all medical records regarding the care and treatment
20 of the plaintiff from January 1, 1994 to present.
21 1 1. Produce a complete set of any and all bills, statements, cancelled checks, schedule of
22 expenses out of pocket expenses medical bills or statements regarding the care and
treatment of the plaintiff from January 1, 1994 to present, which you intend to, will or may
23 present at the time of trial to support your claim for special damages or other economic
loss.
24 12. Produce any and all documents in your possession regarding the 22 job applications
25 referred to in paragraph 28 of the Amended Complaint, that the plaintiff has in her
possession now or in the future should additional documents become available, which
26 have not been produced by the defendant through the discovery process in this lawsuit,
and she which intends to, will or may rely upon, for any purpose, at the time of trial.
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Case 2:O3—cv—O2300-ROS Document 79-4 Filed O2/O9/2006 Page 3 of 4

I Dated this day of October 2005.
2 PAUL K. CHARLTON
3 United States Attorney
District of Arizona
4
5 JOHN R. MAYFIELD
Assistant U.S. Attorney
6
Original and copy of the
7 foregoing HAND-DELIVERED this
day of October 2005 to:
8 Rosval A. Patterson
Attorney at Law
9 Patterson & Associates, P.C.
777 East Thomas Road # 210
10 Phoenix, Arizona 85014
Attorneys for plaintiff
1 1 Copy of the forgoing mailed
12 this day o October 2005 to:
Dana Heck, Attorney
13 Office of Regional Counsel
Department of Veterans Affairs
14 650 East Indian School Road, Building 24
Phoenix, Arizona 85012·1839
15 3225 North Central Avenue, Room 305
Phoenix, Arizona 85012
16
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Case 2:03-cv-02300-ROS

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