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TO: Plaintiff Weltee Wolo, Pro Se, 3140 Northdale Blvd NW, Coon Rapids, Minnesota
55433, [email protected].
Defendant Whispering Pines Assisted Living, Inc (“Defendant”), as and for its answers,
responses and objections to Plaintiff’s Interrogatories to Defendant (First Set) states as follows:
GENERAL OBJECTIONS
1. Defendant objects to the Interrogatories to the extent that they seek information
protected by the attorney-client privilege, work-product doctrine, other applicable privilege, or
information that is protected by the Minnesota Rules of Civil Procedure, federal law, or
Minnesota law.
2. Defendant objects to the Interrogatories to the extent they are overly broad in
terms of time and/or scope, unduly burdensome, oppressive, vague, ambiguous, harassing, and/or
unreasonable.
3. Defendant objects to the Interrogatories to the extent they seek information not
relevant to any party’s claims or defenses, and are not proportional to the needs of the case,
considering the importance of the issues at stake in the actions, the amounts in controversy, the
parties’ relative access to relevant information, the parties’ resources, the importance of the
STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF ANOKA TENTH JUDICIAL DISTRICT
Case Type: Employment
Weltee Wolo,
Plaintiff,
vs.
Whispering Pines Assisted Living, Inc.,
Defendant.
Case No. ___________________
DEFENDANT’S ANSWERS TO
PLAINTIFF’S INTERROGATORIES TO
DEFENDANT (FIRST SET)
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discovery in resolving the issues, and whether the burden or expense of the proposed discovery
outweighs its likely benefit.
4. Defendant objects to the Interrogatories to the extent they seek information that is
already within Plaintiff’s possession, custody, or control, and is already within the knowledge of
Plaintiff.
5. Defendant objects to the Interrogatories to the extent they are more appropriately
directed at a third party.
6. Defendant objects to the Interrogatories to the extent they: (i) seek information
that is beyond the scope of discovery allowed pursuant to the Minnesota Rules of Civil
Procedure and/or other discovery guidelines; or (ii) seek to impose upon Defendant duties or
obligations beyond the scope of the applicable rules or governing authorities. Defendant does
not acquiesce, object to, and decline to be bound by Plaintiff’s definitions and instructions to the
extent that such definitions and instructions seek to impose burdens or obligations on Defendant
beyond those imposed by the Minnesota Rules of Civil Procedure.
7. Defendant objects to the Interrogatories to the extent they assume or require
Defendant to reach or state a legal conclusion.
8. Defendant objects to the Interrogatories as premature to the extent they seek
Defendant’s ultimate factual or legal contentions prior to the close of discovery.
9. Defendant has not completed their investigation or discovery regarding the
relevant facts. Accordingly, Defendant’s responses are based upon information known to
Defendant as of the present date and subject to the reservation of rights set forth below.
10. Defendant objects to the Interrogatories to the extent that they seek discovery of
confidential, trade secret, proprietary, financial, or commercially sensitive documents or
information, the disclosure of which would constitute an invasion of the constitutionally-
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protected right of privacy or could result in substantial competitive injury to Defendant’s
employer or breach by Defendant of an obligation to another to maintain such information as
confidential.
11. All of the General Objections set forth herein are incorporated by reference into
each and every specific Answer to each of Plaintiff’s Interrogatories, and all of the General
Objections shall have the same force and effect as if set forth fully therein. In the interest of
clarity, certain objections may be referred to specifically with respect to a particular
Interrogatory, but the failure to specifically restate a General Objection shall not be construed as
a waiver of any such objection, nor shall such lack of an objection be deemed an admission that
Defendant possess any of the information needed to respond to a particular Interrogatory.
DEFENDANT’S RESERVATION OF RIGHTS
Defendant makes the objections and responses herein without waiver of and with express
reservation regarding:
(a) all questions as to competency, relevancy, materiality, privilege and admissibility as evidence for any purpose, of its response or subject matter thereof, in any subsequent
proceeding in, or the trial of, this or any other action;
(b) the right to object to the use of any of said responses, or subject matter thereof, in any subsequent proceeding in, or the trial of, this or any other action;
(c) the right to object on any ground at any time to a demand for further response to these or any other discovery requests or other discovery procedures involving or relating to
the subject matter of the Interrogatories herein answered; and
(d) the right at any time to revise, correct, add to, or clarify any of the responses provided herein.
DEFENDANT’S OBJECTIONS AND ANSWERS TO INTERROGATORIES
INTERROGATORY NO. 1:
Identify all individual who provided information, were consulted, or participated in the
preparation of the Answer to these Interrogatories, and specify the particular Answer(s) for which each
person was consulted, furnished information, or participated in preparing.
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ANSWER TO INTERROGATORY NO. 1:
Subject to and without waiving the foregoing General Objections, Defendant answers as
follows: Sharon Compton and Breanne Engberg were consulted in connection with the
preparation of the Answers to these Interrogatories. Jaclyn Vados also previously furnished
information used in the preparation of the Answers to these Interrogatories.
INTERROGATORY NO. 2:
Identify all individuals whom you believe have any information or knowledge, or claim
to have the same, with respect to any facts or matters relating to the allegations made in Plaintiffs
Complaint or Defendant's Answer. With respect to each individual, state the subject matter of
their knowledge, the date, place, and circumstances that Defendant obtained the knowledge, and
whether a statement was taken, and the individual’s address and telephone number.
ANSWER TO INTERROGATORY NO. 2:
In addition to the General Objections, Defendant objects that this Interrogatory is vague
and ambiguous. Defendant further objects to this Interrogatory on the grounds that it is unduly
burdensome. Defendant also objects to this Interrogatory on the grounds that it seeks information
that is already within Plaintiff’s possession, custody, or control, and is already within the
knowledge of Plaintiff. Defendant further objects to this Interrogatory to the extent it seeks
information protected by the attorney-client privilege or work product doctrine. Subject to and
without waiving the foregoing Specific and General Objections, Defendant answers as follows:
Defendant refers Plaintiff to the persons identified in the parties’ Initial Disclosures
served in this matter, who may have personal knowledge and/or information relating to the
allegations in Plaintiff’s Complaint and the litigation in this matter. Further, individuals
identified in documents produced by the parties and individuals identified during any witness
deposition testimony may have personal knowledge or information relating to the allegations in
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Plaintiff’s Complaint and the litigation in this matter. Defendant reserves the right to supplement
this response as discovery is ongoing.
INTERROGATORY NO. 3:
Identify all documents known to you which you know or believe may contain facts or
information related to the claims asserted in Plaintiffs Complaint or Defendant’s Answer.
ANSWER TO INTERROGATORY NO. 3:
In addition to the General Objections, Defendant objects that this Interrogatory is
overboard and unduly burdensome, particularly because it purports to require Defendant to
identify “all documents” that may contain any facts or information whatsoever related to any of
the claims asserted in Plaintiff’s Complaint or Defendant’s Answer. Defendant also objects to
this Interrogatory on the grounds that it seeks information that is already within Plaintiff’s
possession, custody, or control, and is already within the knowledge of Plaintiff. Defendant
further objects to this Interrogatory to the extent it seeks information protected by the attorney-
client privilege or work product doctrine. Subject to and without waiving the foregoing Specific
and General Objections, Defendant answers that the documents identified in the parties’ Initial
Disclosures may contain facts or information related to the allegations in Plaintiff’s Complaint
and the litigation in this matter. Further, documents identified and produced by the parties and
documents identified during any witness deposition testimony may contain facts or information
related to the allegations in Plaintiff’s Complaint and the litigation in this matter. Defendant
reserves the right to supplement this response as discovery is ongoing.
INTERROGATORY NO. 4:
With respect to Plaintiff, state the date of her original hire, all employment end dates, all
employment rehire dates, and her salary or rate of pay during each period of employment
beginning in 2017 - present, her total earnings for her entire employment, all
promotions/raises/bonuses/demotions received, all job titles, and all fringe benefits received
including holidays vacation pay, pension plans, and insurance/benefit programs.
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ANSWER TO INTERROGATORY NO. 4:
In addition to the General Objections, Defendant objects that this Interrogatory is
overboard and unduly burdensome, particularly regarding the scope and time of materials sought.
Defendant further objects that this Interrogatory seeks information that is not relevant to any
party’s claim or defense and is not proportional to the needs of the case. Defendant also objects
to this Interrogatory on the grounds that it seeks information that is already within Plaintiff’s
possession, custody, or control, and is already within the knowledge of Plaintiff. Defendant
further objects to this Interrogatory to the extent it seeks information protected by the attorney-
client privilege or work product doctrine. Subject to and without waiving the foregoing Specific
and General Objections, Defendant answers as follows:
To the best of its present understanding and believe, Defendant believes that Plaintiff was
first hired as a Certified Nurse Assistant (“CNA”) in 09/2010 at a rate of $10.55/hr. This rate was
then increased to $13/hr. Plaintiff voluntarily left in 04/2016. Plaintiff’s second employment
period began on 06/15/2018, again as a CNA, at a rate of $16.50/hr. Plaintiff voluntarily left on
10/13/2018. Plaintiff’s third employment period began on 01/22/2019, again at $16.50/hr.
Plaintiff went on maternity leave in 04/2019. Plaintiff voluntarily left on 10/15/2019. Plaintiff’s
fourth employment period began on 02/24/2020, as a Team Lead, at a rate of $20/hr. Plaintiff
voluntarily left on 5/15/2020, purportedly due to COVID daycare issues. Finally, Plaintiff’s fifth
employment period began on 10/24/2020, as a CNA, at a rate of $17.50/hr. Further, documents
produced by Defendant pursuant to Minn. R. Civ. P. 33.03 may contain relevant facts or
information.
INTERROGATORY NO. 5:
Identify each employee, officer, or agent of Defendant who was consulted or participated
in the decision to terminate Plaintiffs employment with Defendant. Include the individual(s) full
name, title, dates of employment, and reason for separation from Defendant, if applicable.
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ANSWER TO INTERROGATORY NO. 5:
In addition to the General Objections, Defendant objects that this Seeks confidential and
sensitive non-party personnel information that is not relevant to any party’s claim or defense.
Subject to and without waiving the foregoing Specific and General Objections, Defendant
answers as follows:
Vice President Sharon Compton, Director of Nursing Jacklyn Vados, HR Representative
Sadie Stoll, and RHIT Sonja Johnson were consulted with and/or participated in the decision to
terminate Plaintiff’s employment in December 2020.
INTERROGATORY NO. 6:
Identify all of Plaintiffs direct or indirect supervisors when she worked at Defendant.
Include the individual(s) full name, current and all previous job titles and dates of each, the
reason for separation from Defendant, if applicable.
ANSWER TO INTERROGATORY NO. 6:
In addition to the General Objections, Defendant objects that this Interrogatory is vague
and ambiguous as to the term “indirect supervisors.” Defendant further objects that this
Interrogatory seeks confidential and sensitive non-party personnel information that is not
relevant to any party’s claim or defense and is not proportional to the needs of the case. Subject
to and without waiving the foregoing Specific and General Objections, Defendant answers as
follows:
CNAs typically report to nurses, who in turn report to the Director of Nursing. During
her last stint of employment, Plaintiff would therefore have reported to RN Dawn Hirsch and
Director of Nursing Jacklyn Vados.
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INTERROGATORY NO. 7:
Identify all individuals at Defendant who were ever subject to the direct or indirect supervision
of any individual responsive to Interrogatory No. 5 or 6 since January 1, 2016. Include the individual(s)
full name, current and previous job titles and dates of each, the reason for separation from Defendant, if
applicable.
ANSWER TO INTERROGATORY NO. 7:
In addition to the General Objections, Defendant objects that this Interrogatory is
overboard and unduly burdensome, as Defendant has nearly 100 employees and dozens, if not
hundreds, of additional former employees during the time period sought by this Interrogatory.
Defendant further objects that this Interrogatory seeks information that is not relevant to any
party’s claim or defense and is not proportional to the needs of the case. Defendant also objects
to this Interrogatory on the grounds that it seeks highly sensitive and confidential non-party
personnel information. See, e.g., Onwuka v. Federal Express Corp., 178 F.R.D. 508, 517 (D.
Minn. 1997) (“[T]he proper balance, between the privacy interests of non-party third persons,
and the discovery interests of a party litigant, is to assure that only those portions of the pertinent
personnel files, which are clearly relevant to the parties’ claims, are open to disclosure and, then,
subject to an appropriate Confidentiality Order as the circumstances require.”). Subject to and
without waiving the foregoing Specific and General Objections, Defendant answers as follows:
Defendant is available, through its counsel, to meet and confer with Plaintiff regarding a
revised version of this interrogatory that is narrowly tailored for the disclosure of relevant
information, if any, about non-party employees, from a shorter time frame, following the entry of
an adequate protective order preserving and ensuring the confidentiality of any sensitive and/or
confidential non-party information.
INTERROGATORY NO. 8:
For the period from January 1, 2017 to the date of your response, identify every
employee at Defendant. As to each employee, state their name, title, dates of employment,
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whether they have worked remotely over the past 2 years, name of direct supervisor, and the
reason the employee separated from Defendant, if applicable.
ANSWER TO INTERROGATORY NO. 8:
In addition to the General Objections, Defendant objects that this Interrogatory is
overboard and unduly burdensome. Defendant further objects that this Interrogatory seeks
information that is not relevant to any party’s claim or defense and is not proportional to the
needs of the case. Defendant also objects to this Interrogatory on the grounds that it seeks highly
sensitive and confidential non-party personnel information. See, e.g., Onwuka v. Federal
Express Corp., 178 F.R.D. 508, 517 (D. Minn. 1997) (“[T]he proper balance, between the
privacy interests of non-party third persons, and the discovery interests of a party litigant, is to
assure that only those portions of the pertinent personnel files, which are clearly relevant to the
parties’ claims, are open to disclosure and, then, subject to an appropriate Confidentiality Order
as the circumstances require.”).
INTERROGATORY NO. 9:
Identify the individual(s) who assumed any of Plaintiffs job duties after her termination
until the date of your response and state the individual's date(s) of employment, age, race,
position, and the reason for the employee's separation from Defendant, if applicable.
ANSWER TO INTERROGATORY NO. 9:
In addition to the General Objections, Defendant to this Interrogatory on the grounds that
it seeks highly sensitive and confidential non-party personnel information. Defendant further
objects to this Interrogatory to the extent it seeks information that is not relevant to any party’s
claim or defense. Subject to and without waiving the foregoing Specific and General Objections,
Defendant answers as follows:
Defendant is available, through its counsel, to meet and confer with Plaintiff regarding
this interrogatory.
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INTERROGATORY NO. 10:
Identify all statements Defendant has obtained in any form from any person regarding
any of the events or happenings concerning Plaintiffs employment and termination of
employment with Defendant. For each such statement, identify:
a. the content and/or substance of the statement; b. whether the statement was oral, written, before a court reporter, recorded or otherwise
preserved;
c. the name, address, and telephone number of the person from whom such statement was taken; and
d. the date, time, and location of the statement.
ANSWER TO INTERROGATORY NO. 10:
In addition to the General Objections, Defendant objects that this Interrogatory as it seeks
a legal conclusion regarding the meaning of the term “statements.” Defendant further objects to
this Interrogatory to the extent it seeks information protected by the attorney-client privilege or
work product doctrine. Subject to and without waiving the foregoing Specific and General
Objections, Defendant answers as follows:
Defendant refers Plaintiff to documents produced by Defendant pursuant to Minn. R. Civ.
P. 33.03 that may contain relevant facts or information. Defendant reserve the right to
supplement this response as discovery is ongoing.
INTERROGATORY NO. 11:
Identify all formal and informal document retention policies in effect from January 1, 2017 to
the date of your response, that relate to any documents responsive to Plaintiff's discovery requests.
ANSWER TO INTERROGATORY NO. 11:
In addition to the General Objections, Defendant objects that this Interrogatory as it seeks
information that is not relevant or reasonably related to admissible evidence. Defendant further
objects to this Interrogatory to the extent it seeks information protected by the attorney-client
privilege or work product doctrine. Subject to and without waiving the foregoing Specific and
General Objections, Defendant answers as follows:
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Defendant retains employment-related documents for periods of time required under
applicable state and federal law. In addition, Defendant implemented a litigation hold in
connection with this lawsuit.
INTERROGATORY NO. 12:
Identify all possible sources of electronically stored information (ESI) that include any
documents responsive to Plaintiff's Request for Production of Documents and/or these
interrogatories. As to each, state:
a. the hardware utilized, b. the software utilized, c. the location of the source, d. the custodian of the source, e. whether the source is keyword searchable, f. whether the source is indexed and/or catalogued, g. the location of any index or catalog, h. the type of documents available on the source, i. the employees who use the source in Defendant's course of business, and j. the business purpose of the source
ANSWER TO INTERROGATORY NO. 12:
In addition to the General Objections, Defendant objects that this Interrogatory is
overboard and unduly burdensome. Defendant further objects that this Interrogatory seeks
information that is not relevant to any party’s claim or defense and is not proportional to the
needs of the case. Defendant also objects to this Interrogatory on the grounds that it is vague and
ambiguous. Defendant further objects that this Interrogatory is an improper, compound
interrogatory. Subject to and without waiving the foregoing Specific and General Objections,
Defendant answers as follows:
Defendant maintains an office iPhone that may contain responsive text messages with
Plaintiff. In addition, Defendant uses Gmail as its e-mail service provider. Individual computers
in Defendant’s possession, custody, and/or control may also contain responsive information.
Defendant reserves the right to supplement this response as discovery is ongoing.
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INTERROGATORY NO. 13:
Identify all statements that you allege or believe constitute, contain, describe, or reflect an
admission against the interest of Plaintiff.
ANSWER TO INTERROGATORY NO. 13:
In addition to the General Objections, Defendant objects that this Interrogatory as it seeks
a legal conclusion. Defendant further objects to this Interrogatory to the extent it seeks
information protected by the attorney-client privilege or work product doctrine. Subject to and
without waiving the foregoing Specific and General Objections, Defendant answers as follows:
Defendant refers Plaintiff to the documents produced by Defendant pursuant to Minn. R.
Civ. P. 33.03 that may contain relevant statements. Defendant reserve the right to supplement
this response as discovery is ongoing.
INTERROGATORY NO. 14:
Identify each instance in which Plaintiff received a performance review during her
employment.
ANSWER TO INTERROGATORY NO. 14:
In addition to the General Objections, Defendant objects that this Interrogatory is vague
and ambiguous. Defendant also objects to this Interrogatory as seeking information that is not
relevant to any party’s claim or defense. Defendant further objects to the extent this
Interrogatory is overbroad and unduly burdensome, in that it seeks documents over a 10-year
period when Plaintiff did not maintain continuous employment with Defendant. Subject to and
without waiving the foregoing Specific and General Objections, Defendant answers as follows:
Defendant refers Plaintiff to the documents produced by Defendant pursuant to Minn. R.
Civ. P. 33.03 that may contain relevant facts or information. Defendant reserve the right to
supplement this response as discovery is ongoing.
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INTERROGATORY NO. 15:
Identify each employee handbook in effect during Plaintiff’s employment with Defendant
and, for each handbook identified, identify the dates during which that handbook was in effect.
ANSWER TO INTERROGATORY NO. 15:
In addition to the General Objections, Defendant objects that this Interrogatory seeks
information that is not relevant to any party’s claim or defense and is not proportional to the
needs of the case. Defendant also objects to this Interrogatory because it is overbroad and
unduly burdensome, in that it seeks all handbooks in effect over the course of a ten-year time
period when Plaintiff did not maintain continuous employment with Defendant. Subject to and
without waiving the foregoing Specific and General Objections, Defendant as follows:
Defendant refers Plaintiff to the documents produced by Defendant pursuant to Minn. R.
Civ. P. 33.03 that may contain relevant facts or information, including the employee handbook
from January 2019, which was in effect during Plaintiff’s final two years of employment with
Defendant.
INTERROGATORY NO. 16:
Identify and describe in detail each instance in which Plaintiff complained of
discrimination to Defendant.
ANSWER TO INTERROGATORY NO. 16:
In addition to the General Objections, Defendant objects that this Interrogatory seeks
information that is already within Plaintiff’s possession, custody, or control, and is already
within the knowledge of Plaintiff. Subject to and without waiving the foregoing Specific and
General Objections, Defendant answers that the documents produced by Defendant pursuant to
Minn. R. Civ. P. 33.03 contain relevant facts and information. Defendant is also aware that
Plaintiff formally filed a charge of discrimination on 12/26/2020, labeled EEOC #26E-2021-
00059. Defendant reserve the right to supplement this response as discovery is ongoing.
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INTERROGATORY NO. 17:
Identify all employees who were employed in the same position as Plaintiff.
ANSWER TO INTERROGATORY NO. 17:
In addition to the General Objections, Defendant objects that this Interrogatory is
overboard and unduly burdensome due to being indefinite as to time period, and because it seeks
information relating to approximately 60 current employees and dozens, if not hundreds, of
former employees. Defendant further objects that this Interrogatory seeks information that is not
relevant to any party’s claim or defense and is not proportional to the needs of the case.
Defendant also objects to this Interrogatory on the grounds that it seeks highly sensitive and
confidential non-party personnel information. See, e.g., Onwuka v. Federal Express Corp., 178
F.R.D. 508, 517 (D. Minn. 1997) (“[T]he proper balance, between the privacy interests of non-
party third persons, and the discovery interests of a party litigant, is to assure that only those
portions of the pertinent personnel files, which are clearly relevant to the parties’ claims, are
open to disclosure and, then, subject to an appropriate Confidentiality Order as the circumstances
require.”).
INTERROGATORY NO. 18:
For each individual identified in your answer to Interrogatory No. 17, please provide the
following:
a. The employee’s date of hire; b. The employee’s starting wage; c. The employee’s race;
ANSWER TO INTERROGATORY NO. 18:
In addition to the General Objections, Defendant objects that this Interrogatory is
overboard and unduly burdensome due to being indefinite as to time period, and because it seeks
personnel information relating to approximately 60 current employees and dozens, if not
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hundreds, of former employees. Defendant further objects that this Interrogatory seeks
information that is not relevant to any party’s claim or defense and is not proportional to the
needs of the case. Defendant also objects to this Interrogatory on the grounds that it seeks highly
sensitive and confidential non-party personnel information. See, e.g., Onwuka v. Federal
Express Corp., 178 F.R.D. 508, 517 (D. Minn. 1997) (“[T]he proper balance, between the
privacy interests of non-party third persons, and the discovery interests of a party litigant, is to
assure that only those portions of the pertinent personnel files, which are clearly relevant to the
parties’ claims, are open to disclosure and, then, subject to an appropriate Confidentiality Order
as the circumstances require.”).
INTERROGATORY NO. 19:
State whether you paid Plaintiff her earned but unpaid PTO at the time of her termination.
ANSWER TO INTERROGATORY NO. 19:
In addition to the General Objections, Defendant objects that this Interrogatory to the
extent it seeks a legal conclusion. Subject to and without waiving the foregoing Specific and
General Objections, Defendant as follows:
Plaintiff was not entitled to the payout of any “earned but unpaid PTO” at the time of her
termination in December 2020. The operative policy in effect at the time of Plaintiff’s
termination states as follows:
Termination Policy Regarding Vacation Pay
An employee who voluntarily terminates employment will only be paid for
accrued vacation time; provided a two week, written notice is given. Unused
vacation time may not be used as part of an employees [sic] 2 week notice.
Unused vacation pay will be processed and paid out in the subsequent payroll pay
periods.
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Plaintiff did not voluntary terminate her employment, and she did not provide a two week,
written notice in advance of voluntary termination. See also documents produced pursuant to
Minn. R. Civ. P. 33.03.
INTERROGATORY NO. 20:
Describe in detail your investigation into the allegations raised against Plaintiff,
including:
a. The name of each employee interviewed; b. The date on which such employee was interviewed; c. Whether you took notes during the interview; and d. Summarize what each such employee stated during the interview.
ANSWER TO INTERROGATORY NO. 20:
In addition to the General Objections, Defendant objects that this Interrogatory is
overboard and unduly burdensome. Subject to and without waiving the foregoing Specific and
General Objections, Defendant answers as follows:
Another employee, Wendy Naylor, made an unsolicited complaint to Whispering Pines’
management about an incident of potential emotional abuse of a vulnerable adult by Plaintiff.
The employee submitted an incident report, which was reviewed by Defendant’s Director of
Nursing, Jacklyn Vados. Ms. Vados interviewed the employee who made the complaint,
reviewed surveillance footage of the incident, interviewed the client subject to the potential
abuse, interviewed Nicole, the LPN for the assisted living home where the incident took place,
and interviewed Plaintiff. Defendant also refers Plaintiff to responsive documents produced
pursuant to Minn. R. Civ. P. 33.03.
INTERROGATORY NO. 21:
State whether an employee (current or former) has ever filed a charge of discrimination against
you, commenced a lawsuit against you, or threatened a lawsuit against you. For each such individual,
identify the following:
a. His/her name;
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b. The basis for the charge, lawsuit, or threatened lawsuit;
c. Whether the matter has been resolved or is ongoing; and
d. The individual's contact information.
ANSWER TO INTERROGATORY NO. 21:
In addition to the General Objections, Defendant objects that this Interrogatory is
overboard and unduly burdensome due to being indefinite as to time period and scope.
Defendant further objects that this Interrogatory seeks information that is not relevant to any
party’s claim or defense and is not proportional to the needs of the case. Subject to and without
waiving the foregoing Specific and General Objections, Defendant answers as follows:
Defendant is available, through its counsel, to meet and confer with Plaintiff regarding a
revised version of this interrogatory that is narrowly tailored for the disclosure of relevant
information from a reasonable time period.
INTERROGATORY NO. 22:
State whether you have every disciplined any employee for engaging in inappropriate
conduct relating to race or racism and, if your answer is in the affirmative, provide the name of
each employee who has been disciplined and describe the disciplinary action taken against each
such employee.
ANSWER TO INTERROGATORY NO. 22:
In addition to the General Objections, Defendant objects that this Interrogatory is
overboard and unduly burdensome due to being indefinite as to time period and scope.
Defendant further objects that this Interrogatory seeks information that is not relevant to any
party’s claim or defense and is not proportional to the needs of the case. Subject to and without
waiving the foregoing Specific and General Objections, Defendant answers as follows:
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Defendant is available, through its counsel, to meet and confer with Plaintiff regarding a
revised version of this interrogatory that is narrowly tailored for the disclosure of relevant
information from a reasonable time period.
AS TO OBJECTIONS:
Dated: November 29, 2021 SPENCER FANE LLP
By: /s/ Randi J. Winter
Randi J. Winter, #0391354
Jose A. Castro, #0399696
100 South Fifth Street, Suite 2500
Minneapolis, MN 55402
Telephone: (612) 268-7000
Facsimile: (612) 268-7001
Attorneys for Defendant Whispering Pines Assisted
Living, Inc.
AS TO ANSWERS:
I declare under penalty of perjury that the foregoing is true and correct to the best of my
knowledge.
Dated: Whispering Pines Assisted Living, Inc.
/s/
By:
Its:
