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Winfield Plaintiff Depo

Winfield Plaintiff Depo

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Published by the kingfish
Depo given by plaintiff in lawsuit against Vicksburg Mayor Paul Winfield
Depo given by plaintiff in lawsuit against Vicksburg Mayor Paul Winfield

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Published by: the kingfish on Feb 27, 2013
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02/27/2013

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IN THE UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF MISSISSIPPIWESTERN DIVISIONKENYA BURKS PLAINTIFFVS. CIVIL ACTION NO. 5:12-cv-00019-DCB-JMRCITY OF VICKSBURG, MISSISSIPPI ANDPAUL WINFIELD, INDIVIDUALLY ANDIN HIS OFFICIAL CAPACITY DEFENDANTS
PLAINTIFF’S RESPONSES TO
DEFENDANT,
PAUL WINFIELD’S,
 FIRST SET OF INTERROGATORIESINTERROGATORY NO. 1.:
State your full name, any other name (includingany nicknames) that you have used or been known by during your lifetime, address,telephone number, cell phone number, personal electronic mail address, work electronic
mail address, Social Security number, drivers’ license number, and date of birth. State
any other addresses, telephone numbers, cell phone numbers, personal electronic mailaddresses, and work electronic mail addresses that you have had in the past five years.
RESPONSE:
Name:Kenya BurksKenya Burks
 –
Shorter  Address:P.O. Box 82Lake Providence, LASS# xxx-xx-DL# MS DL -LA DL (I think)MS DL XXXXX (My first MS DL number was my social until they changed thatnumbering method to a more secure numbering system).TX DL
 –
 
I don’t remember the DL number I had in TX
 
Case 5:12-cv-00019-DCB-MTP Document 68-8 Filed 02/07/13 Page 1 of 32
EXHIBIT “H
 
2
DOB#Telephone numbers:Previous Cell #Cell #Current cell #Email Address:Work Email Address:
5 Years Work Address: I don’t
remember my exact work email addresses, but theywould be some variation of my name:
INTERROGATORY NO. 2.:
Identify the user name and email address for any Facebook account maintained by you from July 2009 through the present.
RESPONSE:
Plaintiff objects to this interrogatory as seeks information thatis irrelevant, overly broad, unduly burdensome, and would likely lead a violation of theComputer Fraud and Abuse Act, 18 U.S.C. § 1030; the Store Communications Act, 18U.S.C. §§ 2701-2712; and the Wiretap Act, as amended by the Electronic PrivacyCommunications Act ("EPCA"), 18 U.S.C. §§ 2510-2522. Notwithstanding, myFacebook account is
INTERROGATORY NO. 3.:
Provide the name, address and telephonenumber of each and every person who has knowledge or information of any relevantfacts concerning any matter raised by any pleading in this action and describe in detail
the substance of that person’s knowledge.
 
RESPONSE:
Plaintiff objects to this interrogatory as it is overly broad andvague.
 Anderson v. UPS, Inc.,
2010 U.S. Dist. LEXIS 123878 *6 (D. Kan. Nov. 22,2010);
 Aikens v. Deluxe Fin. Servs., Inc.,
217 F.R.D. 533, 538 (D. Kan. 2003);
Hilt v.SFC Inc.,
170 F.R.D. 182, 186-7 (D. Kan. 1997);
Stephens v. City of Chi,
203 F.R.D.
Case 5:12-cv-00019-DCB-MTP Document 68-8 Filed 02/07/13 Page 2 of 32
 
3
353, 361-2 (N.D. Ill. 2008). Notwithstanding,
please see Plaintiff’s Pre
-discoverydisclosures.
INTERROGATORY NO. 4.:
Identify each person you expect to call as anexpert witness at trial and, with respect to each person, provide the followinginformation:(a) The subject matter on which he or she is expected to testify;(b) The facts and opinions to which he or she is expected to testify;(c) The grounds for each opinion to which he or she is expected to testify;(d) His or her occupation and profession;(e) His or her job title or position and the name, address and telephonenumber of his or her employer;(f) His or her educational background, including the names of all institutionsattended, the dates of attendance and the degrees received.
 RESPONSE:
Plaintiff has not designated an expert at this time but willsupplement this response if she does.
INTERROGATORY NO. 5.:
Identify each supervisor, co-worker, agent andother person associated with the City of Vicksburg who you believe has sexuallyharassed you or treated you unlawfully or improperly, and, for each individual identified,state the basis of your contention that he or she sexually harassed you or otherwisetreated you unlawfully or improperly, describing without limitation (1) all allegedlyimproper or unlawful acts of each individual identified; (2) the date, time and location of each alleged act; (3) all persons who witnessed each alleged act or have knowledge
Case 5:12-cv-00019-DCB-MTP Document 68-8 Filed 02/07/13 Page 3 of 32

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