I.

INTERROGATORIES
Interrogatory No. 1: Identify the full name and address of all Defendants.
Interrogatory No. 2: Identify

the

person

or

persons

answering

these

interrogatories under oath on behalf of Defendants.

Interrogatory No. 3: Identify each and every person having knowledge of any
facts relevant to the subject matter of this action.
Interrogatory No. 4: As to each person listed in response to the preceding
interrogatory, provide a description of the facts that Defendants contend such person has
knowledge of, and set forth separately for each, the source or basis of such knowledge.
Interrogatory No. 5: Identify each person whom Defendants intend to call as a
witness at the trial of this matter and set forth for each witness a description of each and
every fact as to which said witness will testify.
Interrogatory No. 6: State whether Defendants have obtained or have knowledge
of any statement or admission from Plaintiff relevant to the allegations in the Complaint
and/or Answer in this action. If the answer is in the affirmative:
a.

Identify the date, place and circumstances under which such statement or

admission was made, the person to whom given, and all witnesses thereto;
b.

If the statement or admission is written, identify each and every document

constituting the statement or admission, and provide a copy thereof;

c.

If the statement or admission is oral, but recorded, identify the recording

or transcript, and identify the person who has custody of such items, and provide a copy
thereof; and

d.

If the statement or admission is oral, but not recorded, identify and set

forth a complete verbatim recitation of the statement or admission.

If a verbatim

recitation is not recalled, set forth the substance of the statement or admission.
Interrogatory No. 7: State whether any admission or statement relevant to the
allegations of the Complaint and/or Answer in this action was made by Defendants. If
the answer is in the affirmative:
a.

Identify the date, place and circumstances under which such statement or

admission was made, the person to whom given, and all witnesses thereto;
b.

If the statement or admission is written, identify each and every document

constituting the statement or admission, and provide a copy thereof;

c.

If the statement or admission is oral, but recorded, identify the recording

or transcript, and identify the person who has custody of such items, and provide a copy
thereof; and
d.

If the statement or admission is oral, but not recorded, identify and set

forth a complete verbatim recitation of the statement or admission.

If a verbatim

recitation is not recalled, set forth the substance of the statement or admission.
Interrogatory No. 8: State whether Defendants have obtained or have any
knowledge of any admission or statement from any person, not a party to this action,
relevant to the allegations of the Complaint and/or Answer in this action. If the answer is
in the affirmative:
a.

Identify the date, place and circumstances under which such statement or

admission was made, the person to whom given, and all witnesses thereto;

b.

If the statement or admission is written, identify each and every document

constituting the statement or admission, and provide a copy thereof;

c.

If the statement or admission is oral, but recorded, identify the recording

or transcript, and identify the person who has custody of such items, and provide a copy
thereof; and
d.

If the statement or admission is oral, but not recorded, identify and set

forth a complete verbatim recitation of the statement or admission.

If a verbatim

recitation is not recalled, set forth the substance of the statement or admission.
Interrogatory No. 9: Identify the dates and times of any training(s) of Plaintiffs
supervisors regarding personnel policies or practices of Defendants, including, but not
limited to, any training regarding discrimination, retaliation or harassment, performance
evaluations, job security, discipline, termination, compensation, or other benefits for the
period from September 2007 to the present. For any such training listed, identify who
conducted the training, what materials were used or distributed at the training, as well as
all the names and last known addresses of all Defendants supervisors who attended the
training(s).
Interrogatory No. 10: Identify any complaints of discrimination, retaliation or
harassment, including but not limited to complaints by Defendants employees, directed
at ALISON COVIELO from 2012 to the present. For each such complaint, identify the
date, location of the incident, persons involved and discipline imposed, if any.
Interrogatory No. 11 Identify any complaints of discrimination, retaliation or
harassment, including but not limited to complaints by Defendants employees, directed
at YOLANDA TORRES from 1995 to the present. For each such complaint, identify the
date, location of the incident, persons involved and discipline imposed, if any.

Interrogatory No. 12: Identify each and every person who supervised the work of
Plaintiff from 2007 to the present, and the dates of supervision by each supervisor.
Interrogatory No. 13: State in full factual detail Defendants version of the events
leading up to the incidents, occurrences, breach, damage, injury or loss described in the
Complaint, identifying these events or occurrences by dates, places and persons involved.
Interrogatory No. 14: Identify the dates of any discussions, meetings, trainings or
monitoring held or arranged by Defendants with regard to any of Defendants policies
regarding discrimination or retaliation, the persons who conducted such discussions,
meetings, trainings or monitoring, any documents provided at such discussions, meetings,
trainings or monitoring and the persons present at such discussions, meetings, trainings or
monitoring.
Interrogatory No. 15: Identify every other claim, charge or complaint of
discrimination, retaliation, harassment (including internal complaints) brought against
Defendant ALISON COVIELLO at all teaching, security, and administrative positions
any time from 2012 to the present, including but not limited to:
a.

The name of the individual(s) bringing each such claim, charge or

complaint;
b.

The nature of each such claim, charge or complaint;

c.

The date each such claim, charge or complaint was brought;

d.

The type of proceeding in which each such claim, charge or complaint was

brought, including the case caption and docket number, if any;

e.

The identity of any attorney who represented each such individual who

raised any claim, charge or complaint; and

f.

The manner in which each such claim, charge or complaint was resolved.
Interrogatory No. 16 Identify every other claim, charge or complaint of

discrimination, retaliation, harassment (including internal complaints) brought against

Defendant YOLANDA TORRES at all teaching, security, and administrative positions
any time from 1995 to the present, including but not limited to:
a.

The name of the individual(s) bringing each such claim, charge or

complaint;
b.

The nature of each such claim, charge or complaint;

c.

The date each such claim, charge or complaint was brought;

d.

The type of proceeding in which each such claim, charge or complaint was

brought, including the case caption and docket number, if any;

e.

The identity of any attorney who represented each such individual who

raised any claim, charge or complaint; and

f.

The manner in which each such claim, charge or complaint was resolved.

Interrogatory No. 17:

Identify all lawsuits or other court actions to which

Defendants ALISON COVIELLO and/or PS 154 has been a party since 2012 to the
present.

Interrogatory No. 18 Identify all lawsuits or other court actions to which

Defendants YOLANDA TORRES and/or District 7, District 9, District 10, MS 399, MS
226, Region 1 has been a party since 1995 to the present.