Rut roh! (And TheRiot is toast)
Definitions and Instructions
a. Neither the word “or” nor the word “and” should be interpreted so as to eliminate any part of any response to any of these Requests.
b. “You” means Defendants, the Parish of Jefferson and Steve J. Theriot, and any of their agents or employees acting within the scope of their agency or employment.
c. “Documents” means anything within the scope of Federal Rule of Civil Procedure 34.
INTERROGATORY NO. 1:
Please identify all at-will Parish employees terminated by the Parish after John Young became Parish President; identify all such employees who refused to submit a resignation letter as a condition of employment.
INTERROGATORY NO. 2:
Please explain, in detail, why the Plaintiff’s employment with the Parish of Jefferson was terminated. Was Plaintiff’s refusal to submit a letter of resignation the sole reason for her termination? If not, please identify any other reasons.
INTERROGATORY NO. 3:
Does the Parish currently require employees to submit letter of resignation as a condition of continued employment? If not, advise why this policy was changed and when.
INTERROGATORY NO. 4:
Do the defendants acknowledge that the Plaintiff was cooperating with Federal authorities in corruption investigations? If so, please identify all persons with knowledge of Plaintiff’s cooperation, the dates that they became aware, and any adverse action, response, emails, memoranda or correspondence generated in response to Plaintiff’s cooperation.
INTERROGATORY NO. 5:
Identify the nature of any and all complaints which the Plaintiff made regarding any illegal or irregular conduct of any Parish employee, administrator, or official, including the person to whom this complaint was made, the date it was made, the form of the complaint (oral or written), and any response or action taken in response to same.
INTERROGATORY NO. 6:
Identify all discussions, meetings, telephone calls, emails, memoranda, or other forms of communication which John Young had with any person regarding the decision to terminate Plaintiff, including the date of the communication and its substance, in detail; with respect to any written or recorded communications, please produce a copy of same.
INTERROGATORY NO. 7:
Please advise, in detail, why Plaintiff was denied access to research services (such as Westlaw), was removed from the email distribution list, and not apprised of policy implementations or changes which applied to other employees. Identify all individuals who had any role in making decisions regarding these actions.
REQUEST FOR PRODUCTION NO. 1:
Please produce all emails, memoranda, letters, or other correspondence that in any way relate to the requirement that employees submit resignation letters.
REQUEST FOR PRODUCTION NO. 2:
Please produce any and all emails, memoranda, pamphlets, books, journals, or other writing or documentation of all personnel policies in effect in the one year prior to Plaintiff’s termination and one year thereafter.
REQUEST FOR PRODUCTION NO. 3:
Please produce any and all emails, memoranda, letters, or other correspondence generated or received by Steve J. Theriot and John Young which discuss, mention, or refer to, in any manner, the Plaintiff by name, initials, position or pejorative.
REQUEST FOR PRODUCTION NO. 4:
Please produce all emails, memoranda, or correspondence relating to any communications regarding the Plaintiff’s cooperation with any and all Federal authorities.
REQUEST FOR PRODUCTION NO. 5:
Please produce all emails, memoranda, or correspondence relating to any communications regarding the Plaintiff’s denial of access to research services (such as Westlaw), her removal from the email distribution list, and the failure to apprise her of policy implementations or changes which applied to other employees.