UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY LEXINGTON DIVISION CIVIL ACTION CASE NO. 5:09-cv-00244-KSF C. MARTIN GASKELL PLAINTIFF V. DEFENDANT UNIVERSITY OF KENTUCKY'S RESPONSES TO PLAINTIFF'S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS. ELECTRONICALLY-STORED INFORMATION AND TANGIBLE THINGS UNIVERSITY OF KENTUCKY DEFEN DANT ** ** 9|C$ ** ** ** *% ** Comes the Defendant, University of Kentucky, by counsel, and for its Responses to the Plaintiffs First Set of Requests for Production of Documents, Electronically Stored Information and Tangible Things, states as follows: REQUEST NO. 1: Any and all documents, correspondence, tangible things, and electronically stored information that Defendant (its agents or third-parties) sent to, prepared for, or received from the federal Equal Employment Opportunity Commission, the Kentucky Commission on Human Rights, or any other agency or entity concerning Plaintiffs allegations against Defendant. RESPONSE: OBJECTION. The documents requested are not subject to discovery as they were prepared in anticipation of litigation and are work product. Without waiving this OBJECTION, see documents under Tab 1. REQUEST NO. 2: Any and all documents, correspondence, tangible things, and electronically stored information concerning any investigation by Defendant, its agents, or third parties of the events set forth in the Complaint filed in this action. Case: 5:09-cv-00244-KSF-REW Doc #: 55-1 Filed: 12/22/10 Page: 1 of 9 - Page ID#: 2261
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12/22/10: Defense Response to Plaintiff's Requests - … of Interrogatories to Defendant. RESPONSE: Documents referenced in Defendant's Answers to Plaintiffs First Set of ... VERIFICATION
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UNITED STATES DISTRICT COURTEASTERN DISTRICT OF KENTUCKY
LEXINGTON DIVISIONCIVIL ACTION CASE NO. 5:09-cv-00244-KSF
C . M A R T I N G A S K E L L P L A I N T I F F
V. DEFENDANT UNIVERSITY OF KENTUCKY'S RESPONSESTO PLAINTIFF'S FIRST SET OF REQUESTS FOR
PRODUCTION OF DOCUMENTS. ELECTRONICALLY-STOREDINFORMATION AND TANGIBLE THINGS
U N I V E R S I T Y O F K E N T U C K Y D E F E N D A N T
* * * * 9 | C $ * * * * * * * % * *
Comes the Defendant, University of Kentucky, by counsel, and for its Responses to the
Plaintiffs First Set of Requests for Production of Documents, Electronically Stored Information
and Tangible Things, states as follows:
REQUEST NO. 1: Any and all documents, correspondence, tangible things, and
electronically stored information that Defendant (its agents or third-parties) sent to, prepared for,
or received from the federal Equal Employment Opportunity Commission, the Kentucky
Commission on Human Rights, or any other agency or entity concerning Plaintiffs allegations
against Defendant.
RESPONSE: OBJECTION. The documents requested are not subject to discovery as
they were prepared in anticipation of litigation and are work product. Without waiving this
OBJECTION, see documents under Tab 1.
REQUEST NO. 2: Any and all documents, correspondence, tangible things, and
electronically stored information concerning any investigation by Defendant, its agents, or third
parties of the events set forth in the Complaint filed in this action.
I hereby certify that a true and accurate copy of the foregoing pleading has been servedby mail upon the following parties on this the JO day of fuJlfAAAdUvf , 2010:
Original to:Geoffrey R. SurteesFrancis J. ManionAmerican Center for Law & Justice6375 New Hope RoadNew Hope, KY 40052andEdward L. White, IIIAmerican Center for Law & Justice5068 Plymouth RoadAnn Arbor, Ml 48105Counsel for Plaintiff