Byron L. Mills,
Nevada Bar No.
703 S. 8th
Telephone: (702) 386-0030
Attorneys for Plaintiff .
CLARK COUNTY, NEVADA
Clyde Wilson )
Plaintiff, ) Dept.
Dice & Jacobs Law Firm )
FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS
TO: CHARLES JACOBS, Defendant;
Plaintiff, Clyde Wilson,
by his undersigned attorneys, requests that Defendant, Charles Jacobs,
answer the following interrogatories under oath pursuant to NRCP 33, within
thirty (30) days.
The following preliminary
statement and definitions apply to each of the Interrogatories set forth
hereinafter and are deemed to be incorporated therein:
1. These Interrogatories call for all information (including
information contained in writings) that is known or available to you or your
attorney or others acting on your behalf or under your direction.
2. Whenever you are asked to identify a person in answer to any
(a) Their name;
(b) Their last known address;
you are asked to identify a writing, please state a full description, including
but not limited to:
(a) The date;
(b) The name of the person who prepared it;
(c) The name of each person to whom it was
(d) Its subject matter and its substance.
you are unable to state an answer to these Interrogatories based upon your
personal knowledge, please state so, and instead identify the people of which
you believe to have this knowledge.
1. The term “you” or “your” means
the Defendant, and all other persons acting or purporting to act on Defendant’s
2. The term “document” means each original and
copy, regardless of origin and location of any written or recorded
material, including computer stored and computer retrievable information.
3. The term “and”
means and/or and the term “or” means and/or.
NO. 1: Explain the Defendant’s exact reasoning
in the termination of the Plaintiff’s employment in full detail including any incompetency
or inadequate work performance.
PRODUCTION NO. 1: Provide all current and previous employee files
from the year of 2000 up to current date, including but not limited to:
Complaints and warnings
NO. 2: Identify all people/employees/colleagues
who have knowledge of facts or statements concerning the allegations given.
PRODUCTION NO. 2: Produce all
documents concerning all known people’s knowledge of facts relevant to the
allegations made in the previously entered Complaint.
NO. 3: Please list
any and all people who the Defendant will call as a witness at trial and provide
a brief summary of their testimony.
REQUEST FOR PRODUCTION NO. 3: Provide any documents concerning the witness/witnesses
listed by Defendant in the above response to Plaintiff’s Interrogatory No. 3.
NO. 4: Identify all people/employees/colleagues
with who the Defendant has communicated with concerning the allegations made
and describe in detail.
PRODUCTION NO. 4: Produce any
documents concerning the communications described in Plaintiff’s Interrogatory
NO. 5: Identify all people who have filed
a complaint against or concerning the Defendant’s conduct in the workplace. Any
complaints regarding employment discrimination or a hostile work environment,
describe in detail and any accompanying actions or reprimands made by the Defendant.
REQUEST FOR PRODUCTION NO. 5: Produce all documents concerning any and all complaints
identified regarding employment discrimination or a hostile work environment from