LEONARD HARP, et al.

*
* IN THE CIRCUIT COURT
Plaintiffs * FOR
* BALTIMORE CITY
v. *
*
GOVERNOR LARRY HOGAN , et al. *
STATE OF MARYLAND *
100 State Circle *
Annapolis, MD 21401 *
* Case No.: 24-C-21-2999
Defendant *
*
* * * * * * * * * * * * *

PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO

DEFENDANT TIFFANY ROBINSON

INSTRUCTIONS

(a) Pursuant to Md. Rule 2-421(b), you are required to answer the
following Interrogatories within thirty (30) days after service of the Interrogatories.

(b) Also in accordance with Rule 2-421(b), your Answers shall set forth the
Interrogatory, and shall set forth the Answer to the Interrogatory “separately and fully in writing
under oath” or “shall state the grounds for refusal to answer” any Interrogatory. Your Answers
shall be signed by you.

(c) Also in accordance with Rule 2-421(b), your Answers “shall include all
information available” to you “directly or through agents, representatives, or attorneys.”

(d) Pursuant to Rule 2-401(e), these Interrogatories are continuing in nature. If

you obtain further material information before trial, you are required to supplement your
Answers promptly.

(e) If, pursuant to Rule 2-421(c), you elect to specify and produce business
records of yours in answer to any Interrogatory, your specification shall be in sufficient
detail to enable the interrogating party to locate and identify the records from which the
Answer may be ascertained.

(f) If you perceive any ambiguities in any Interrogatory, instruction, or

definition, set forth the matter deemed ambiguous, and the construction used in answering.

DEFINITIONS

In these Interrogatories, the following definitions apply:

 (a) The words “any” and “all” shall be read in the conjunctive and not in the
disjunctive wherever they appear, and neither of these words shall be interpreted to limit the
scope of an Interrogatory. Furthermore, the use of a verb in any tense shall be construed as
the use of the verb in all other tenses, and the singular form shall be deemed to include the
plural, and vice-versa. The singular form of any noun shall be deemed to include the plural,
and vice-versa.

(b) “Document” includes electronically stored information and any writing,

drawing, graph, chart, photograph, sound recording, image, and other data or data
compilation stored in any medium from which information can be obtained and translated, if
necessary, through detection devices into reasonably usable form.

(c) “Identify,” “identity,” or “identification” (1) when used in reference to a natural

person, means that person’s full name, last known address, home and business telephone
numbers, and present occupation or business affiliation; (2) when used in reference to a person
other than a natural person, means that person’s full name, a description of the nature of the
person (that is, whether it is a corporation, partnership, etc. under the definition of person
below), and the person’s last known address, telephone number, and principal place of
business; (3) when used in reference to any person after the person has been properly identified
previously means the person’s name; and (4) when used in reference to a document, requires
you to state the date, the author (or, if different, the signer or signers), the addressee, the
identity of the present custodian of the document, and the type of document (e.g., letter,
memorandum, telegram, or chart) or to attach an accurate copy of the document to your
Answer, appropriately labeled to correspond to the Interrogatory.

(d) “Person” includes an individual, general or limited partnership, joint stock

company, unincorporated association or society, municipal or other corporation, incorporated
association, limited liability partnership, limited liability company, professional corporation,
the State, an agency or political subdivision of the State, a court, and any other governmental
entity.

(e) The terms “you” and “your” refer to Maryland Secretary of Labor Tiffany M.
Robinson, together with any attorneys, agents, representatives, or persons acting on behalf of
any of the foregoing.

(f) “Agreement” refers to the Agreement Implementing the Relief for Works
Affected by Coronavirus Act between the State of Maryland and the Secretary of Labor, U.S.
Department of Labor.

(g) “CARES Act Benefits” refers to the unemployment insurance benefits provided
through the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act, codified as 15
U.S.C.
 INTERROGATORIES

1. You contend that the Harp et. al. plaintiffs have not exhausted administrative remedies
regarding “on-hold” status for CARES Act Benefits, please state the basis of that
contention.

2. You contend that the Harp et. al. plaintiffs have not exhausted administrative remedies
regarding identity verification for CARES Act Benefits, please state the basis of that
contention.

3. State the criteria used by the Department of Labor when making the determination to
place a CARES Act Benefits claimant in “on-hold” status.

4. State the criteria used by the Department of Labor when making the determination to
require identity verification from a CARES Act Benefits claimant.

5. State the number of times the BEACON system has experienced technical problems
resulting in accounts being locked out or a system-wide crash.

6. State the number of claimants required to reapply through the BEACON system for
CARES Act Benefits eligibility determination between June 1, 2021, and June 10, 2021.

7. State the basis for requiring claimants to reapply through the BEACON system for a
CARES Act Benefits eligibility determination between June 1, 2021, and June 10, 2021
through the BEACON system.

8. State the number of outstanding claims for CARES Act Benefits as of September 13,
2021.

9. State the number of claims under the CARES Act currently pending identity verification.

10. State the number of claims under the CARES Act currently in “on-hold” status.

11. State the single Department of Labor point of contact established to oversee and prioritize
the resolution of claims that have not been completed within eight weeks per Labor and
Employment Article §8-109(a)(8) of the Maryland Annotated Code.

12. State the number of claims for CARES Act Benefits that have not been resolved in eight
weeks or less.
Respectfully submitted,

UNEMPLOYED WORKERS UNION

____________________________
Alec Summerfield, CPF #1906060002
2011 N. Charles Street
Baltimore, MD 21230
(443) 324-8644
Asummerfield@protonmail.com
 CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing first set of interrogatories was mailed this 14th

day of September, 2021, by certified, postage prepaid, United States Mail, on:

Christopher R. Mellott
CRMellott@Venable.com
Geoffrey R. Garinther
GRGarinther@Venable.com
Ashleigh J. F. Lynn
AJLynn@Venable.com
Elizabeth C. Rinehart
LCRinehart@Venable.com
Anthony J. Vitti
AJVitti@Venable.com
Venable LLP 750 E. Pratt Street, Suite 900
Baltimore, Maryland 21202

Attorneys for Defendants

ALEC SUMMERFIELD, CPF #1906060002

Pro Bono Attorney
Unemployed Workers Union
2011 N. Charles Street
Baltimore, MD 21218
(443) 324-8644