‘THE HONORABLE ROBERT S. LASNIK 2 3 4 5 6 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE 9) LOANITA ADAMS, No, C11-0995 RSL 0 Plaintiff, 0 v. OFFICER SCHMIDT'S RESPONSES TO PLAINTIFF'S INTERROGATORIES 12) cury OF FEDERAL WAY, etal, B Defendants TO: Plaintiff Loanita Adams Officer Keith Schmidt answers Plaintiff's Inerrogatories a follows ‘NOTE: Officer Schmidt's business address is 33325 8th Ave S, Federal Way, WA 98003 INTERROGATORY NO. 1: On Janvary 22, 2011 approximately at 10:30pm, could you explain why you arrived at a residence located on 32211 11th PIS. unit #84 in Federal Way WA? ANSWER: Officer Sant and I were responding to a 911 hang up call and addtional 21) 91 calls from neighbors reporting a domestic disturbance at apartment #84 23) mvrERROGATORY NO.2: Upon aval, what wae your observation? SCHMIDT'S INTERROGATORY RESPONSES- 1 Cause No, C11-0995.RSL arose BUKLN MCCORRACK INC PS20 2 2 2B 4 ANSWER: Upon arrival, I observed two femles, identified at T. Edwards and L. ‘Adams. Officer Sant spoke with L. Adams and I spoke with T. Edwards, INTERROGATORY NO. 3: Were there any visible injuries detected? and if s0, 10 ‘whom? ANSWER: I observed a cut to the inside of . Rdwarde!hottom lip and a ext to T. Edwards’ left elbow. INTERROGATORY N ‘Were there other spectators involved? ANSWER: There was a witness named H. Hanis present INTERROGATORY Nt for an arrest? Did you make an arrest” and if so, what was your reasoning. ANSWER: Officer Sant placed L. Adams uncer ast for DV Assault 4 based on witness accounts of what had occurred; he bad probable cause to believe that L. Adams was the primary aggressor in a physical altercation with her daughter. INTERROGATORY N Were there statements provided? and if so, by whom? ANSWER: Yes, T. Edwards, H. Harris and L. Adams provided verbal statements atthe scene and H. Harris provided a written statement INTERROGATORY NO. 7: Did Ms. Adams provide a statement? ANSWER: Yes, she spoke with Officer Sant atthe scene. She did not provide a swriten statement. INTERROGATORY NO. 8: Did you file a report onthe incident? ANSWER: The reports on the incident are attached, ‘SCHMIDT'S INTERROGATORY RESPONSES-2 Gao No Ch RS gre, Bu EMCCERNACK INES ta amen?19 20 21 2 23 4 INTERROGATORY NO. 9: Were you aware thatthe involved individuals were mother ‘and daughter? ANSWER: Yes, I became aware ofthat through the investigation process. INTERROGATORY NO. 10: Were you assisted with another officer? And ifs, Did you confer determination with tis officer? ANSWER: 1 was considered the primary officer on this case and Officer Sant assisted. We were in agreement that there was probable cause to arrest L. Adams for DV ‘Assault in the 4th Degree. INTERROGATORY NO. 11: Did the officer assisted in the atest? ANSWER: I do not understand the question as written. I was present when Officer Sant placed you under amest, but do not believe I had to “assist” with your actual acest, aside from my role inthe investigation atthe sene. cs ficate of Keith Schmit, being frst duly sworn on oath, deposes an¢ says Tam one ofthe above-named defendants, ard have read the foregoing response to Plaintiff's Interrogatories, know the contents thereof, and believe the same to be true tothe best of my knowledge. DATED this 2/577 day of February, 2011 at Federal Way, Washington, ALIS ‘Oificer Keith Schmidt SCHMIDT'S INTERROGATORY RESPONSES-3 Cause No. CIOO9S-RS1, earn CHL A MCCORCKING, BS.ATTORNEY'S CR26 CERTIFICATION The undersigned attomey certifies, pursuant to Civil Role 26(g), that he has read ‘each response and objection t0 these discovery requests, and that, to the best of his knowledge, information, and belief formed after a reasonable inquiry, each is:(1) consistent with the Civil Rules and warranted by existing law or good-faith argument for the extension, modification, or reversal of existing law; (2) not interposed for any improper purpose, such as to harass or to cause unnecessary delay or needless increase in the costs of litigation; and (3) aot unreasonably or unduly burdensome or expensive, given the needs of the case, discovery already had in the case, the amount in controversy, and the importance of the issues at stake inthe litigation DATED this Dean of February 2012. oe #3975 pie Teh] Pires, WSBA BSS the Defendant Schmidt SCHMIDT'S INTERROGATORY RESPONSES. 4 Gane No. C1295 RSL Kear ORL A MECOMNAC, Ne, PS.