1 TO Plaintiff Weltee Wolo, Pro Se, 3140 Northdale Bl

1
TO: Plaintiff Weltee Wolo, Pro Se, 3140 Northdale Blvd NW,
Coon Rapids, Minnesota
55433, [email protected]
Defendant Whispering Pines Assisted Living, Inc
(“Defendant”), as and for its answers,
responses and objections to Plaintiff’s Interrogatories to
Defendant (First Set) states as follows:
GENERAL OBJECTIONS
1. Defendant objects to the Interrogatories to the extent that
they seek information
protected by the attorney-client privilege, work-product
doctrine, other applicable privilege, or
information that is protected by the Minnesota Rules of Civil
Procedure, federal law, or
Minnesota law.
2. Defendant objects to the Interrogatories to the extent they are
overly broad in
terms of time and/or scope, unduly burdensome, oppressive,

vague, ambiguous, harassing, and/or
unreasonable.
3. Defendant objects to the Interrogatories to the extent they
seek information not
relevant to any party’s claims or defenses, and are not
proportional to the needs of the case,
considering the importance of the issues at stake in the actions,
the amounts in controversy, the
parties’ relative access to relevant information, the parties’
resources, the importance of the
STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF ANOKA TENTH JUDICIAL DISTRICT
Case Type: Employment
Weltee Wolo,
Plaintiff,
vs.
Whispering Pines Assisted Living, Inc.,

Defendant.
Case No. ___________________
DEFENDANT’S ANSWERS TO
PLAINTIFF’S INTERROGATORIES TO
DEFENDANT (FIRST SET)
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discovery in resolving the issues, and whether the burden or
expense of the proposed discovery
outweighs its likely benefit.
seek information that is
already within Plaintiff’s possession, custody, or control, and is
already within the knowledge of
Plaintiff.
5. Defendant objects to the Interrogatories to the extent they are
more appropriately
directed at a third party.

6. Defendant objects to the Interrogatories to the extent they:
(i) seek information
that is beyond the scope of discovery allowed pursuant to the
Minnesota Rules of Civil
Procedure and/or other discovery guidelines; or (ii) seek to
impose upon Defendant duties or
obligations beyond the scope of the applicable rules or
governing authorities. Defendant does
not acquiesce, object to, and decline to be bound by Plaintiff’s
definitions and instructions to the
extent that such definitions and instructions seek to impose
burdens or obligations on Defendant
beyond those imposed by the Minnesota Rules of Civil
Procedure.
assume or require
Defendant to reach or state a legal conclusion.
8. Defendant objects to the Interrogatories as premature to the
extent they seek
Defendant’s ultimate factual or legal contentions prior to the
close of discovery.
9. Defendant has not completed their investigation or discovery
regarding the

relevant facts. Accordingly, Defendant’s responses are based
upon information known to
Defendant as of the present date and subject to the reservation
of rights set forth below.
10. Defendant objects to the Interrogatories to the extent that
they seek discovery of
confidential, trade secret, proprietary, financial, or
commercially sensitive documents or
information, the disclosure of which would constitute an
invasion of the constitutionally-
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protected right of privacy or could result in substantial
competitive injury to Defendant’s
employer or breach by Defendant of an obligation to another to
maintain such information as
confidential.
11. All of the General Objections set forth herein are
incorporated by reference into
each and every specific Answer to each of Plaintiff’s
Interrogatories, and all of the General
Objections shall have the same force and effect as if set forth
fully therein. In the interest of

clarity, certain objections may be referred to specifically with
respect to a particular
Interrogatory, but the failure to specifically restate a General
Objection shall not be construed as
a waiver of any such objection, nor shall such lack of an
objection be deemed an admission that
Defendant possess any of the information needed to respond to a
particular Interrogatory.
DEFENDANT’S RESERVATION OF RIGHTS
Defendant makes the objections and responses herein without
waiver of and with express
reservation regarding:
(a) all questions as to competency, relevancy, materiality,
privilege and admissibility as
evidence for any purpose, of its response or subject matter
thereof, in any subsequent
proceeding in, or the trial of, this or any other action;
(b) the right to object to the use of any of said responses, or
subject matter thereof, in any
subsequent proceeding in, or the trial of, this or any other
action;
(c) the right to object on any ground at any time to a demand for
further response to these
or any other discovery requests or other discovery procedures
involving or relating to

the subject matter of the Interrogatories herein answered; and
(d) the right at any time to revise, correct, add to, or clarify any
of the responses provided
herein.
DEFENDANT’S OBJECTIONS AND ANSWERS TO
INTERROGATORIES
INTERROGATORY NO. 1:
Identify all individual who provided information, were
consulted, or participated in the
preparation of the Answer to these Interrogatories, and specify
the particular Answer(s) for which each
person was consulted, furnished information, or participated in
preparing.
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ANSWER TO INTERROGATORY NO. 1:
Subject to and without waiving the foregoing General
Objections, Defendant answers as
follows: Sharon Compton and Breanne Engberg were consulted
in connection with the

preparation of the Answers to these Interrogatories. Jaclyn
Vados also previously furnished
information used in the preparation of the Answers to these
Interrogatories.
Identify all individuals whom you believe have any information
or knowledge, or claim
to have the same, with respect to any facts or matters relating to
the allegations made in Plaintiffs
Complaint or Defendant's Answer. With respect to each
individual, state the subject matter of
their knowledge, the date, place, and circumstances that
Defendant obtained the knowledge, and
whether a statement was taken, and the individual’s address and
telephone number.
In addition to the General Objections, Defendant objects that
this Interrogatory is vague
and ambiguous. Defendant further objects to this Interrogatory
on the grounds that it is unduly
burdensome. Defendant also objects to this Interrogatory on the

grounds that it seeks information
that is already within Plaintiff’s possession, custody, or control,
and is already within the
knowledge of Plaintiff. Defendant further objects to this
Interrogatory to the extent it seeks
information protected by the attorney-client privilege or work
product doctrine. Subject to and
without waiving the foregoing Specific and General Objections,
Defendant answers as follows:
Defendant refers Plaintiff to the persons identified in the
parties’ Initial Disclosures
served in this matter, who may have personal knowledge and/or
information relating to the
allegations in Plaintiff’s Complaint and the litigation in this
matter. Further, individuals
identified in documents produced by the parties and individuals
identified during any witness
deposition testimony may have personal knowledge or
information relating to the allegations in
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Plaintiff’s Complaint and the litigation in this matter.
Defendant reserves the right to supplement

this response as discovery is ongoing.
Identify all documents known to you which you know or believe
may contain facts or
information related to the claims asserted in Plaintiffs
Complaint or Defendant’s Answer.
this Interrogatory is
overboard and unduly burdensome, particularly because it
purports to require Defendant to
identify “all documents” that may contain any facts or
information whatsoever related to any of
the claims asserted in Plaintiff’s Complaint or Defendant’s
Answer. Defendant also objects to
this Interrogatory on the grounds that it seeks information that
is already within Plaintiff’s
possession, custody, or control, and is already within the
knowledge of Plaintiff. Defendant
further objects to this Interrogatory to the extent it seeks
information protected by the attorney-

client privilege or work product doctrine. Subject to and
without waiving the foregoing Specific
and General Objections, Defendant answers that the documents
identified in the parties’ Initial
Disclosures may contain facts or information related to the
allegations in Plaintiff’s Complaint
and the litigation in this matter. Further, documents identified
and produced by the parties and
documents identified during any witness deposition testimony
may contain facts or information
related to the allegations in Plaintiff’s Complaint and the
litigation in this matter. Defendant
reserves the right to supplement this response as discovery is
ongoing.
With respect to Plaintiff, state the date of her original hire, all
employment end dates, all
employment rehire dates, and her salary or rate of pay during
each period of employment
beginning in 2017 - present, her total earnings for her entire
employment, all
promotions/raises/bonuses/demotions received, all job titles,
and all fringe benefits received

including holidays vacation pay, pension plans, and
insurance/benefit programs.
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overboard and unduly burdensome, particularly regarding the
scope and time of materials sought.
Defendant further objects that this Interrogatory seeks
information that is not relevant to any
party’s claim or defense and is not proportional to the needs of
the case. Defendant also objects
to this Interrogatory on the grounds that it seeks information
that is already within Plaintiff’s
possession, custody, or control, and is already within the
knowledge of Plaintiff. Defendant
further objects to this Interrogatory to the extent it seeks
information protected by the attorney-
client privilege or work product doctrine. Subject to and
without waiving the foregoing Specific

and General Objections, Defendant answers as follows:
To the best of its present understanding and believe, Defendant
believes that Plaintiff was
first hired as a Certified Nurse Assistant (“CNA”) in 09/2010 at
a rate of $10.55/hr. This rate was
then increased to $13/hr. Plaintiff voluntarily left in 04/2016.
Plaintiff’s second employment
period began on 06/15/2018, again as a CNA, at a rate of
$16.50/hr. Plaintiff voluntarily left on
10/13/2018. Plaintiff’s third employment period began on
01/22/2019, again at $16.50/hr.
Plaintiff went on maternity leave in 04/2019. Plaintiff
voluntarily left on 10/15/2019. Plaintiff’s
fourth employment period began on 02/24/2020, as a Team
Lead, at a rate of $20/hr. Plaintiff
voluntarily left on 5/15/2020, purportedly due to COVID
daycare issues. Finally, Plaintiff’s fifth
employment period began on 10/24/2020, as a CNA, at a rate of
$17.50/hr. Further, documents
produced by Defendant pursuant to Minn. R. Civ. P. 33.03 may
contain relevant facts or
information.

Identify each employee, officer, or agent of Defendant who was
consulted or participated
in the decision to terminate Plaintiffs employment with
Defendant. Include the individual(s) full
name, title, dates of employment, and reason for separation
from Defendant, if applicable.
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this Seeks confidential and
sensitive non-party personnel information that is not relevant to
any party’s claim or defense.
Subject to and without waiving the foregoing Specific and
General Objections, Defendant
answers as follows:
Vice President Sharon Compton, Director of Nursing Jacklyn
Vados, HR Representative
Sadie Stoll, and RHIT Sonja Johnson were consulted with
and/or participated in the decision to

terminate Plaintiff’s employment in December 2020.
Identify all of Plaintiffs direct or indirect supervisors when she
worked at Defendant.
Include the individual(s) full name, current and all previous job
titles and dates of each, the
reason for separation from Defendant, if applicable.
and ambiguous as to the term “indirect supervisors.” Defendant
further objects that this
Interrogatory seeks confidential and sensitive non-party
personnel information that is not
relevant to any party’s claim or defense and is not proportional
to the needs of the case. Subject
to and without waiving the foregoing Specific and General
Objections, Defendant answers as
follows:
CNAs typically report to nurses, who in turn report to the
Director of Nursing. During

her last stint of employment, Plaintiff would therefore have
reported to RN Dawn Hirsch and
Director of Nursing Jacklyn Vados.
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Identify all individuals at Defendant who were ever subject to
the direct or indirect supervision
of any individual responsive to Interrogatory No. 5 or 6 since
January 1, 2016. Include the individual(s)
full name, current and previous job titles and dates of each, the
reason for separation from Defendant, if
applicable.
overboard and unduly burdensome, as Defendant has nearly 100
employees and dozens, if not

hundreds, of additional former employees during the time
period sought by this Interrogatory.
the case. Defendant also objects
to this Interrogatory on the grounds that it seeks highly
sensitive and confidential non-party
personnel information. See, e.g., Onwuka v. Federal Express
Corp., 178 F.R.D. 508, 517 (D.
Minn. 1997) (“[T]he proper balance, between the privacy
interests of non-party third persons,
and the discovery interests of a party litigant, is to assure that
only those portions of the pertinent
personnel files, which are clearly relevant to the parties’ claims,
are open to disclosure and, then,
subject to an appropriate Confidentiality Order as the
circumstances require.”). Subject to and
Defendant is available, through its counsel, to meet and confer
with Plaintiff regarding a
revised version of this interrogatory that is narrowly tailored for
the disclosure of relevant

information, if any, about non-party employees, from a shorter
time frame, following the entry of
an adequate protective order preserving and ensuring the
confidentiality of any sensitive and/or
confidential non-party information.
For the period from January 1, 2017 to the date of your
response, identify every
employee at Defendant. As to each employee, state their name,
title, dates of employment,
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whether they have worked remotely over the past 2 years, name
of direct supervisor, and the
reason the employee separated from Defendant, if applicable.
overboard and unduly burdensome. Defendant further objects

that this Interrogatory seeks
information that is not relevant to any party’s claim or defense
and is not proportional to the
needs of the case. Defendant also objects to this Interrogatory
on the grounds that it seeks highly
sensitive and confidential non-party personnel information.
See, e.g., Onwuka v. Federal
Express Corp., 178 F.R.D. 508, 517 (D. Minn. 1997) (“[T]he
proper balance, between the
privacy interests of non-party third persons, and the discovery
interests of a party litigant, is to
assure that only those portions of the pertinent personnel files,
which are clearly relevant to the
parties’ claims, are open to disclosure and, then, subject to an
appropriate Confidentiality Order
as the circumstances require.”).
Identify the individual(s) who assumed any of Plaintiffs job
duties after her termination
until the date of your response and state the individual's date(s)
of employment, age, race,
position, and the reason for the employee's separation from
Defendant, if applicable.

In addition to the General Objections, Defendant to this
Interrogatory on the grounds that
it seeks highly sensitive and confidential non-party personnel
information. Defendant further
objects to this Interrogatory to the extent it seeks information
that is not relevant to any party’s
claim or defense. Subject to and without waiving the foregoing
Specific and General Objections,
with Plaintiff regarding
this interrogatory.
10
Identify all statements Defendant has obtained in any form from
any person regarding
any of the events or happenings concerning Plaintiffs
employment and termination of

employment with Defendant. For each such statement, identify:
a. the content and/or substance of the statement;
b. whether the statement was oral, written, before a court
reporter, recorded or otherwise
preserved;
c. the name, address, and telephone number of the person from
whom such statement
was taken; and
d. the date, time, and location of the statement.
this Interrogatory as it seeks
a legal conclusion regarding the meaning of the term
“statements.” Defendant further objects to
this Interrogatory to the extent it seeks information protected by
the attorney-client privilege or
work product doctrine. Subject to and without waiving the
foregoing Specific and General
Objections, Defendant answers as follows:
Defendant refers Plaintiff to documents produced by Defendant
pursuant to Minn. R. Civ.

P. 33.03 that may contain relevant facts or information.
Defendant reserve the right to
supplement this response as discovery is ongoing.
Identify all formal and informal document retention policies in
effect from January 1, 2017 to
the date of your response, that relate to any documents
responsive to Plaintiff's discovery requests.
information that is not relevant or reasonably related to
admissible evidence. Defendant further
objects to this Interrogatory to the extent it seeks information
protected by the attorney-client
privilege or work product doctrine. Subject to and without
waiving the foregoing Specific and
General Objections, Defendant answers as follows:
11

Defendant retains employment-related documents for periods of
time required under
applicable state and federal law. In addition, Defendant
implemented a litigation hold in
connection with this lawsuit.
Identify all possible sources of electronically stored information
(ESI) that include any
documents responsive to Plaintiff's Request for Production of
Documents and/or these
interrogatories. As to each, state:
a. the hardware utilized,
b. the software utilized,
c. the location of the source,
d. the custodian of the source,
e. whether the source is keyword searchable,
f. whether the source is indexed and/or catalogued,
g. the location of any index or catalog,
h. the type of documents available on the source,
i. the employees who use the source in Defendant's course of
business, and
j. the business purpose of the source

overboard and unduly burdensome. Defendant further objects
that this Interrogatory seeks
on the grounds that it is vague and
ambiguous. Defendant further objects that this Interrogatory is
an improper, compound
interrogatory. Subject to and without waiving the foregoing
Specific and General Objections,
Defendant maintains an office iPhone that may contain
responsive text messages with
Plaintiff. In addition, Defendant uses Gmail as its e-mail
service provider. Individual computers
in Defendant’s possession, custody, and/or control may also
contain responsive information.
Defendant reserves the right to supplement this response as
discovery is ongoing.
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Identify all statements that you allege or believe constitute,
contain, describe, or reflect an
admission against the interest of Plaintiff.
a legal conclusion. Defendant further objects to this
Interrogatory to the extent it seeks
information protected by the attorney-client privilege or work
product doctrine. Subject to and
Defendant refers Plaintiff to the documents produced by
Defendant pursuant to Minn. R.
Civ. P. 33.03 that may contain relevant statements. Defendant
reserve the right to supplement
this response as discovery is ongoing.

Identify each instance in which Plaintiff received a performance
review during her
employment.
and ambiguous. Defendant also objects to this Interrogatory as
seeking information that is not
relevant to any party’s claim or defense. Defendant further
objects to the extent this
Interrogatory is overbroad and unduly burdensome, in that it
seeks documents over a 10-year
period when Plaintiff did not maintain continuous employment
with Defendant. Subject to and
Civ. P. 33.03 that may contain relevant facts or information.
Defendant reserve the right to
supplement this response as discovery is ongoing.

13
Identify each employee handbook in effect during Plaintiff’s
employment with Defendant
and, for each handbook identified, identify the dates during
which that handbook was in effect.
this Interrogatory seeks
because it is overbroad and
unduly burdensome, in that it seeks all handbooks in effect over
the course of a ten-year time
period when Plaintiff did not maintain continuous employment
with Defendant. Subject to and
Defendant as follows:

Civ. P. 33.03 that may contain relevant facts or information,
including the employee handbook
from January 2019, which was in effect during Plaintiff’s final
two years of employment with
Defendant.
Identify and describe in detail each instance in which Plaintiff
complained of
discrimination to Defendant.
information that is already within Plaintiff’s possession,
custody, or control, and is already
within the knowledge of Plaintiff. Subject to and without
General Objections, Defendant answers that the documents
produced by Defendant pursuant to
Minn. R. Civ. P. 33.03 contain relevant facts and information.

Defendant is also aware that
Plaintiff formally filed a charge of discrimination on
12/26/2020, labeled EEOC #26E-2021-
00059. Defendant reserve the right to supplement this response
as discovery is ongoing.
14
Identify all employees who were employed in the same position
as Plaintiff.
overboard and unduly burdensome due to being indefinite as to
time period, and because it seeks
information relating to approximately 60 current employees and
dozens, if not hundreds, of
former employees. Defendant further objects that this
Interrogatory seeks information that is not
relevant to any party’s claim or defense and is not proportional
to the needs of the case.

Defendant also objects to this Interrogatory on the grounds that
it seeks highly sensitive and
confidential non-party personnel information. See, e.g.,
Onwuka v. Federal Express Corp., 178
F.R.D. 508, 517 (D. Minn. 1997) (“[T]he proper balance,
between the privacy interests of non-
party third persons, and the discovery interests of a party
litigant, is to assure that only those
portions of the pertinent personnel files, which are clearly
relevant to the parties’ claims, are
open to disclosure and, then, subject to an appropriate
Confidentiality Order as the circumstances
require.”).
For each individual identified in your answer to Interrogatory
No. 17, please provide the
following:
a. The employee’s date of hire;
b. The employee’s starting wage;
c. The employee’s race;

time period, and because it seeks
personnel information relating to approximately 60 current
employees and dozens, if not
15
hundreds, of former employees. Defendant further objects that
on the grounds that it seeks highly
sensitive and confidential non-party personnel information.
See, e.g., Onwuka v. Federal
Express Corp., 178 F.R.D. 508, 517 (D. Minn. 1997) (“[T]he
proper balance, between the
privacy interests of non-party third persons, and the discovery
interests of a party litigant, is to
assure that only those portions of the pertinent personnel files,
which are clearly relevant to the

parties’ claims, are open to disclosure and, then, subject to an
appropriate Confidentiality Order
as the circumstances require.”).
State whether you paid Plaintiff her earned but unpaid PTO at
the time of her termination.
this Interrogatory to the
extent it seeks a legal conclusion. Subject to and without
General Objections, Defendant as follows:
Plaintiff was not entitled to the payout of any “earned but
unpaid PTO” at the time of her
termination in December 2020. The operative policy in effect at
the time of Plaintiff’s
termination states as follows:
Termination Policy Regarding Vacation Pay
An employee who voluntarily terminates employment will only
be paid for

accrued vacation time; provided a two week, written notice is
given. Unused
vacation time may not be used as part of an employees [sic] 2
week notice.
Unused vacation pay will be processed and paid out in the
subsequent payroll pay
periods.
16
Plaintiff did not voluntary terminate her employment, and she
did not provide a two week,
written notice in advance of voluntary termination. See also
documents produced pursuant to
Minn. R. Civ. P. 33.03.
Describe in detail your investigation into the allegations raised
against Plaintiff,
including:
a. The name of each employee interviewed;

b. The date on which such employee was interviewed;
c. Whether you took notes during the interview; and
d. Summarize what each such employee stated during the
interview.
overboard and unduly burdensome. Subject to and without
General Objections, Defendant answers as follows:
Another employee, Wendy Naylor, made an unsolicited
complaint to Whispering Pines’
management about an incident of potential emotional abuse of a
vulnerable adult by Plaintiff.
The employee submitted an incident report, which was reviewed
by Defendant’s Director of
Nursing, Jacklyn Vados. Ms. Vados interviewed the employee
who made the complaint,
reviewed surveillance footage of the incident, interviewed the
client subject to the potential
abuse, interviewed Nicole, the LPN for the assisted living home
where the incident took place,
and interviewed Plaintiff. Defendant also refers Plaintiff to

responsive documents produced
pursuant to Minn. R. Civ. P. 33.03.
State whether an employee (current or former) has ever filed a
charge of discrimination against
you, commenced a lawsuit against you, or threatened a lawsuit
against you. For each such individual,
identify the following:
a. His/her name;
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b. The basis for the charge, lawsuit, or threatened lawsuit;
c. Whether the matter has been resolved or is ongoing; and
d. The individual's contact information.

time period and scope.
the case. Subject to and without
waiving the foregoing Specific and General Objections,
information from a reasonable time period.
State whether you have every disciplined any employee for
engaging in inappropriate
conduct relating to race or racism and, if your answer is in the
affirmative, provide the name of
each employee who has been disciplined and describe the
disciplinary action taken against each
such employee.

time period and scope.
the case. Subject to and without
waiving the foregoing Specific and General Objections,
18
information from a reasonable time period.
AS TO OBJECTIONS:
Dated: November 29, 2021 SPENCER FANE LLP
By: /s/ Randi J. Winter

Randi J. Winter, #0391354
Jose A. Castro, #0399696
100 South Fifth Street, Suite 2500
Minneapolis, MN 55402
Telephone: (612) 268-7000
Facsimile: (612) 268-7001
[email protected]
[email protected]
Attorneys for Defendant Whispering Pines Assisted
Living, Inc.
AS TO ANSWERS:
I declare under penalty of perjury that the foregoing is true and
correct to the best of my
knowledge.
Dated: Whispering Pines Assisted Living, Inc.
/s/
By:

Its:
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TO: Plaintiff Weltee Wolo through her counsel, Tyler W.
Brennan, Tyler W. Brennan Law,
LLC, T3 Building, 323 N. Washington Avenue, Suite 200,
Minneapolis, MN 55401.
Pursuant to Rule 34 of the Minnesota Rules of Civil Procedure,
Defendant Whispering
Pines Assisted Living, Inc. (“Whispering Pines” or
“Defendant”) requests that Plaintiff Weltee
Wolo (“Wolo” or “Plaintiff”) produce and permit Whispering
Pines to inspect and copy the
following documents, electronically stored information, and
things, within thirty (30) days of the
date of service hereof.
In responding to the following requests, unless the context
indicates otherwise, you are to

construe them in light of the following:
DEFINITIONS
1. The term “Document” shall have the broadest meaning which
can be ascribed to it
pursuant to Rule 26 of the Minnesota Rules of Civil Procedure.
Among other things, the term
“Document” refers to and includes any written, printed, typed or
other graphic matter of any kind
or nature, all computer materials, processes, data and
compilations thereof from which information
can be obtained, including, but not limited to, papers, letters,
correspondence, telegrams, inter-
STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF ANOKA TENTH JUDICIAL DISTRICT
Case Type: Employment
Weltee Wolo,
Plaintiff,
vs.

Whispering Pines Assisted Living, Inc.,
Defendant.
Court File No.
The Honorable
DEFENDANT’S REQUESTS FOR
PRODUCTION OF DOCUMENTS TO
PLAINTIFF (SET I)
2
office communications, memoranda, notes, notations,
notebooks, reports, records, minutes of
meetings, schedules, tables, charges, transcripts, publications,
scrapbooks, diaries, E-mail,
electronic mail, voice mail, electronic bulletin board postings,
tabulations, vouchers, accounts,
statements, affidavits, abstracts, agreements, contracts, diaries,

calendars, plans, specifications,
drawings, sketches, photostats, photographs, charts, graphs and
other similar objects, and any kind
of transcript, transcription or recording of any conversation,
discussion or oral presentation of any
kind, and any information stored on, and reproducible in
documentary form from a computer or
other electronic, magnetic, optical or laser based information
storage device, including but not
limited to floppy disks, hard disks, tapes, backup tapes, CD-
ROM, DVD’s, USB drives, thumb
drives, external data storage devices, handheld PC’s, or PDA’s
and any drafts, revisions or
amendments of the above, in the possession or within the
control of Plaintiff, her attorneys or
agents, or known by Plaintiff to exist, including materials
deemed to be subject to any evidentiary
privilege. The term “Document” specifically includes
Electronically Stored Information.
2. “Electronically Stored Information” or “ESI” shall include all
electronic
information permitted to be discovered under Rule 34 of the
Minnesota Rules of Civil Procedure,
including, without limitation: Internet web pages, word-

processing documents, spreadsheets,
presentation documents, graphics, animations, images, email
(including attachments which shall
be kept with the email), instant messages, text messages, voice
mail, audio, video, and audiovisual
recordings, databases and database subsets, and other user or
machine-created computer files or
other digital information which is stored on computer networks,
servers, computer systems,
desktop computers, laptop computers, home computers, the
Internet, an Intranet, archives, discs,
CD’s, diskettes, drives, zip drives, tapes, cartridges, flash
drives, and other external storage media,
personal digital assistants, handheld wireless devices, smart
phones, cellular telephones,
3
blackberries, pagers, iPhones, iPads, iPods, and voicemail
systems. All of the ESI requested herein
shall be produced with all metadata preserved.
3. The term “Communications” means all forms of oral, written,
and nonverbal

communication, including, but not limited to, communications
taking place face-to-face, via
telephone, facsimile, electronic mail, voice mail, electronic
messaging (e.g., instant messaging),
or by means of correspondence, letters, statements, or
otherwise.
4. The term “Person” refers to and includes natural persons,
corporations,
partnerships, proprietorships, joint ventures, unincorporated
associations, trusts, estates,
governments (and agencies thereof), quasi-public entities, and
other forms of legal entities.
5. The terms “reflecting,” “concerning,” “evidencing,” “referred
to,” “related to,”
“regarding,” “depicted,” or “displayed” mean and include,
without limitation, regarding, showing,
reflecting, referring to, alluding to, responding to, relating to,
connected with, commenting upon,
with respect to, consisting of, comprising, constituting,
discussing, recording, or in any way
touching upon or pertaining to.
6. The singular form of a word shall also refer to the plural, and
words used in the

masculine, feminine, or neuter gender shall refer to and include
all genders.
7. “And” includes the disjunctive “or”; “or” includes the
conjunctive “and.”
8. “Defendant,” “Whispering Pines,” or “WPAL” shall refer to
Whispering Pines
Assisted Living, Inc., as well as its agents, attorneys, or anyone
acting or purporting to act on its
behalf.
9. “You” or “Your” shall refer to Plaintiff Weltee Wolo, as well
as her agents,
attorneys, or anyone acting or purporting to act on her behalf.
4
10. “Plaintiff” or “Wolo” shall refer to Plaintiff Weltee Wolo,
as well as her agents,
attorneys, or anyone acting or purporting to act on her behalf.
11. “Complaint” shall mean the Complaint filed and served by
Plaintiff in the above-
captioned matter, and any subsequent amendments thereto.
12. “Answer” shall mean the Answer served by Defendant in

the above-captioned
matter, and any subsequent amendments thereto.
DOCUMENT-SPECIFIC INSTRUCTIONS
13. You are requested and required to produce each Document
designated below that
is within your care, custody, or control or otherwise available,
including Documents in the
possession of your attorneys, accountants, advisors, or other
persons directly or indirectly acting
for you or with you. If all Documents requested cannot be
produced in their entirety, produce each
Document requested to the extent possible, specify the reason
for the inability to produce the
remaining Documents, and state whatever information or
knowledge you have regarding the
unproduced Documents. If you maintain that any Document has
been destroyed, set forth the
contents of the Document, the location of any copies of the
Document, the date of and reason for
such destruction, and the name and address of all persons who
ordered, authorized, or participated
in such destruction.
14. If any Document is withheld from production on the basis of

privilege or otherwise,
identify each such Document and the grounds upon which
production of each Document is being
withheld. Include:
(a) the date;
(b) the author;
(c) the type of Document;
5
(d) the addressee(s) or other intended recipient(s);
(e) the title, heading, or other designation numerical on the
Document; and
(f) the privilege type and basis for the privilege.
15. These Requests shall be deemed continuing so as to require
supplemental responses

if ACA obtains further information between the times responses
are served and the time of trial.
REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: All Documents and Communications that You
referred to, relied
upon, consulted, or used in any way to draft the Complaint,
Your Initial Disclosures, and/or Your
responses to Defendant’s First Set of Interrogatories to
Plaintiff.
REQUEST NO. 2: All Documents and Communications relating
to, referring to,
supporting, and/or refuting any of the allegations in the
Complaint.
to, referring to,
supporting, and/or refuting the allegation that Defendant failed
to pay You for Your accrued,
unused vacation time, as set forth in paragraphs 9 and 35–38 of
the Complaint.
to, referring to,
supporting, and/or refuting the allegation that Defendant’s
stated reason for terminating You is a

mere pretext for discrimination and reprisal and/or has no
factual basis, as set forth in paragraphs
14–15 of the Complaint.
to, referring to,
supporting, and/or refuting the allegation that Defendant failed
to pay You earned wages within
24 hours of Your demand, as set forth in paragraphs 19 and 31–
34 of the Complaint.
to, referring to,
supporting, and/or refuting the allegation that Defendant’s
decision to terminate Your employment
6
otherwise occurred under circumstances that give rise to an
inference of unlawful discrimination,
as set forth in paragraphs 20–24 of the Complaint.
to, referring to,
supporting, and/or refuting the allegation that Defendant took
adverse actions against You in

reprisal to activity protected under MHRA, as set forth in
paragraphs 25–30 of the Complaint.
to, referring to,
supporting, and/or refuting your allegation that other employees
of Defendant were similarly
situated to You, but treated more favorably than You, as set
forth in paragraphs 25–30 of the
Complaint.
to, referring to, and/or
reflecting any and all complaints of any kind that You allege to
have made to Defendant at any
time.
REQUEST NO. 10: All Documents and Communications
relating to, referring to, and/or
reflecting any and all reports of discrimination and/or reprisal
that You allege to have made to
Defendant at any time.
REQUEST NO. 11: Journals, diaries, calendars, appointment
books, agendas,
notebooks, and notes written or maintained by You from 2018
through and including the present

relating to or referring to any of the allegations in the
Complaint and/or Your employment with
Defendant.
relating to Your employment
with Whispering Pines Assisted Living, Inc. and any change in
Your employment status, job
duties, promotions, and/or job transfers, including but not
limited to all contracts, agreements,
memoranda, policies, handbooks, complaints filed, performance
reviews, performance
7
improvement plans, warnings, disciplinary actions, termination
notices, resignation letters, and
reports that are related to any of the allegations in the
Complaint.
REQUEST NO. 13: All Documents that are the property of
Whispering Pines Assisted
Living, Inc. or that you removed or directed to be removed from
Whispering Pines Assisted Living,

Inc.'s premises, including but not limited to its physical
premises and computer systems.
REQUEST NO. 14: All Documents relating to, referring to,
supporting, and/or refuting
the alleged discriminatory culture which existed in the
workplace, as alleged in paragraph 12 of
the Complaint.
submitted to or received from,
the U.S. Equal Employment Opportunity Commission (EEOC),
the Minnesota Department of
Human Rights (MDHR), and/or the Minnesota Department of
Employment and Economic
Development (DEED), including but not limited to documents
relating to any charges of
discrimination and/or applications for unemployment benefits
that You have made since 2016.
relating to any administrative
charge or proceeding or lawsuit to which You were a party
within the last ten years relating to
Your employment with any Employer that rely on or are similar
or related to the factual allegations
or claims at issue in this lawsuit.

relating to any complaint of
harassment, discrimination, or retaliation that you alleged
against any employer within the last ten
years.
relating to Your efforts to seek
employment from December 11, 2020, through and including
the present, including but not limited
to any resumes, applications for employment, cover letters,
reference letters, job inquiries, offers
8
of employment, employment agreements, independent contractor
and consulting agreements or
arrangements, job advertisements or postings, rejection letters,
and any other communications with
any Employer.
relating to the termination of
Your employment from any Employer, whether voluntary or

involuntary, occurring at any time
after the end of Your employment with Whispering Pines
Assisted Living, Inc.
relating to any training or
education that You have applied for or received from December
11, 2020, through and including
the present.
REQUEST NO. 21: Documents sufficient to show any income
or other compensation
received by or owed to You, including but not limited to
paychecks, paystubs, invoices, settlement
payments, statements of work, Form W-2s, Form 1099s, social
security benefits, social security
disability benefits, unemployment insurance benefits, workers'
compensation benefits, and long-
term or short-term disability benefits from December 11, 2020,
through and including the present.
REQUEST NO. 22: Your federal and state income tax returns
for the tax years 2020
through and including the present, including all supporting
documentation.
relating to, referring to,

supporting, and/or refuting Your claim for damages in this
lawsuit, including but not limited to
documents relating to the claim for damages as set forth in
paragraphs 20–38 of the Complaint,
your initial disclosures, and/or the calculation of damages
claimed.
relating to, referring to,
supporting, and/or refuting any injuries, including physical,
mental, and emotional injuries, You
allegedly sustained as a result of Whispering Pines Assisted
Living, Inc.’s conduct from 2018
9
through and including the present, including but not limited to
all medical records and
psychotherapy notes.
REQUEST NO. 25: Completed and executed authorization forms
for the release of
medical records and psychotherapy notes for each physician,
psychiatrist, psychologist, therapist,

social worker, or other healthcare professional identified in
response to Interrogatory Number 11
of Defendant’s First Set of Interrogatories to Plaintiff with
whom You have consulted and/or from
whom You have received or sought treatment.
relating to and/or referring to
each expert you intend to call as a witness at trial, including but
not limited to all Documents and
Communications sent to or received from each expert, resumes,
curriculum vitae, and reports.
REQUEST NO. 27: All affidavits, sworn statements, notes, and
other documents sent to,
received from, or otherwise relating to any person you intend to
call as a witness at trial, either in
person, through deposition testimony, or through an affidavit
regarding, referring, and/or relating
to any claim or allegation in this Action.
REQUEST NO. 28: All affidavits, sworn statements, and
communications regarding,
referring, and/or relating to any claim in this Action.
REQUEST NO. 29: All social media postings relating to any of
the allegations in the

Complaint, including but not limited to postings on Facebook,
LinkedIn, Twitter, YouTube,
Instagram, Snapchat, TikTok, blogs, wikis, and other social
media sites.
REQUEST NO. 30: All Documents and Communications that
contain or otherwise relate
to facts that you contend refute, in any way, any of Defendant’s
defenses in this Action.
REQUEST NO. 31: A complete copy of all the Facebook
information from January 1,
2018, to the present, for any Facebook account currently or
previously maintained by You. You
10
can download a complete copy of such information by loggi ng
into each applicable Facebook
account, choosing “Settings & Privacy,” choosing “Settings,”
choosing “Your Facebook
Information,” and then choosing “Download Your Information.”
On the “Download Your
Information” page, you can then select the date range of January
1, 2018 to the present, selecting

a Media Quality of “High” or “Medium,” and selecting “HTML”
as the Format before clicking
“Create File.”
REQUEST NO. 32: All Documents identified in Section 2 of
Your Initial Disclosures.
Dated: November 19, 2021 SPENCER FANE LLP
By: /s/ Randi J. Winter
Randi J. Winter, #0391354
Jose A. Castro, #0399696
100 South Fifth Street, Suite 2500
Minneapolis, MN 55402
Telephone: (612) 268-7000
Facsimile: (612) 268-7001
[email protected]
Attorneys for Defendant Whispering Pines Assisted
Living, Inc.

1 TO Plaintiff Weltee Wolo, Pro Se, 3140 Northdale Bl

1 TO Plaintiff Weltee Wolo, Pro Se, 3140 Northdale Bl

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