Sample Interrogatories and Requests For Production in a Discrimination Lawsuit

By James Samuel Bell -

(1) Please produce a copy of the record of the victim. If any documents composing a portion of this information have already been produced, please identify such documents.

(2) Has the complaining witness, or any other person ever requested a copy of his/her record relating to employment with you? If the answer is ”yes,” please state:

(a) Date upon which request was received;

(b) Whether a copy of the file was provided, and if so, the date of production, the manner in which the copy was provided, and identification of documents provided;

(c) Whether any material was added to the file following receipt of Plaintiff’s request; and

(d) Whether any material was deleted from her information following receipt of our request.

(3) Do you admit that you received a letter requesting our client’s personnel record on or about [date]? If your answer is no, please state when you first received a written request for personnel record.

(4) Do you admit that on 2030, John Doe, provided a copy of our client’s file to you?

(5) Are any documents included in our client’s record that were not produced by you.

(6) Did any of her supervisors or any other employee of yours keep an ”unofficial” file on our client, including documents that are not contained in the official personnel record? If your answer is ”yes,” please identify who kept such a file and produce copies of documents contained in each such ”unofficial” personnel file.

(7) Do you have any documents relating to the hiring of our client? If your answer is ”yes,” please produce copies of all such documents.

(8) Was an exit interview conducted with our client? If your answer is ”yes,” please identify who conducted the interview.

(9) Were any documents generated that relate to any exit interview or other conversation with Jane Doe after her termination of employment was announced? If your answer is ”yes,” please produce copies of all such documents.

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