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)
2
discovery in resolving the issues, and whether the burden or expense of the proposed discovery
outweighs its likely benefit.
4. Defendant objects to the Interrogatories to the extent they 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.
7. Defendant objects to the Interrogatories to the extent they 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
rel ...
Defendants Hyatt Corporation, AB/FH DFW Property, LLC, and The Services Companies filed an original answer in response to a lawsuit filed by Jacquelyn Medina. The defendants made a general denial of all claims and allegations in the plaintiff's petition. They asserted 13 defenses including sole proximate cause, failure to mitigate damages, contributory negligence, and rights under Texas civil practice law. The defendants joined the plaintiff's request for a jury trial and requested the plaintiff disclose information required under Texas rules of civil procedure.
This document provides information about navigating the process for challenging an agency's decision to deny or reduce disability services under Florida law. It outlines the 6 key steps in the process: 1) filing a petition by the deadline indicated in the denial notice, 2) being assigned a hearing officer and case number, 3) preparing for the hearing, 4) compiling documents and witness statements to support the case, 5) preparing witnesses, and 6) attending the hearing guided by the hearing officer.
Good legal verbiage defendants objection on the grounds of relevancy-californiascreaminc
- Plaintiff filed a motion to compel Defendants to respond to interrogatories and document requests. Defendants did not respond to the motion in a timely manner but requested to file a late response.
- The court found that Defendants provided an adequate explanation for the late response and allowed it to be filed. In their response, Defendants objected that the discovery requests were irrelevant and that there were too many interrogatories.
- The court overruled Defendants' objections, finding that the discovery sought was relevant to proving Plaintiff's claims. The court granted Plaintiff's motion to compel and ordered Defendants to comply with the discovery requests. However, the court denied Plaintiff's request for expenses related to bringing the motion.
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This document outlines the proper procedure for conducting a domestic inquiry when taking disciplinary action against an employee in India according to law. It discusses why domestic inquiries are necessary, the principles of natural justice that must be followed, and the steps involved in the disciplinary procedure including: issuing a charge sheet, holding a suspension if needed, considering the employee's explanation, issuing an inquiry notice, conducting the inquiry, preparing the inquiry report, and the final decision by the punishing authority. The overall summary is that this document provides a detailed guide to properly conducting a fair domestic inquiry when disciplining an employee according to Indian law.
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This document outlines the proper procedure for conducting a domestic inquiry under Indian law when taking disciplinary action against an employee. Key points include:
1) A fair inquiry must be conducted according to principles of natural justice before an employer can punish an employee for misconduct.
2) The inquiry officer must give the employee a chance to defend themselves by examining witnesses and evidence against them.
3) The management bears the burden of proving the charges, and the employee must be considered not guilty unless proven otherwise.
4) If conducted properly and without bias, the employer's decision is unlikely to be overturned even if challenged.
Defendants Hyatt Corporation, AB/FH DFW Property, LLC, and The Services Companies filed an original answer in response to a lawsuit filed by Jacquelyn Medina. The defendants made a general denial of all claims and allegations in the plaintiff's petition. They asserted 13 defenses including sole proximate cause, failure to mitigate damages, contributory negligence, and rights under Texas civil practice law. The defendants joined the plaintiff's request for a jury trial and requested the plaintiff disclose information required under Texas rules of civil procedure.
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Good legal verbiage defendants objection on the grounds of relevancy-californiascreaminc
- Plaintiff filed a motion to compel Defendants to respond to interrogatories and document requests. Defendants did not respond to the motion in a timely manner but requested to file a late response.
- The court found that Defendants provided an adequate explanation for the late response and allowed it to be filed. In their response, Defendants objected that the discovery requests were irrelevant and that there were too many interrogatories.
- The court overruled Defendants' objections, finding that the discovery sought was relevant to proving Plaintiff's claims. The court granted Plaintiff's motion to compel and ordered Defendants to comply with the discovery requests. However, the court denied Plaintiff's request for expenses related to bringing the motion.
This document is a court decision in an Article 78 proceeding brought by Sheri Glederman against New York education officials. Glederman, a teacher, received a growth score of 1 out of 20 for the 2013-2014 school year, designating her performance as "ineffective". She challenged this score as arbitrary. The court found that Glederman has standing to bring the case because her growth score dropped significantly from the prior year, lowering her overall rating and harming her reputation. The court denied the motion to dismiss and reserved on Glederman's request for discovery pending the administrative record.
This document outlines the proper procedure for conducting a domestic inquiry when taking disciplinary action against an employee in India according to law. It discusses why domestic inquiries are necessary, the principles of natural justice that must be followed, and the steps involved in the disciplinary procedure including: issuing a charge sheet, holding a suspension if needed, considering the employee's explanation, issuing an inquiry notice, conducting the inquiry, preparing the inquiry report, and the final decision by the punishing authority. The overall summary is that this document provides a detailed guide to properly conducting a fair domestic inquiry when disciplining an employee according to Indian law.
The Kielich Law Firm provides a brief discussion of discovery devices used in Texas litigation such as car accidents, divorce, employment discrimination and other lawsuits in Texas courts and federal courts.
The following presentation describes a recently passed, and soon to be signed, Indiana law regarding how to address the problem of bad-faith assertions of patent infringement by patent assertion entities, sometimes referred to as "patent trolls." The law provides a definition of what constitutes bad faith assertion of patent infringement as well as gives guidance on basic information that is required for patent cease and desist or demand letters. It also provides procedures for having the entity post a pre-trial bond and/or be subject to damages or other remedies for bad faith assertion of patent infringement.
This document outlines the proper procedure for conducting a domestic inquiry under Indian law when taking disciplinary action against an employee. Key points include:
1) A fair inquiry must be conducted according to principles of natural justice before an employer can punish an employee for misconduct.
2) The inquiry officer must give the employee a chance to defend themselves by examining witnesses and evidence against them.
3) The management bears the burden of proving the charges, and the employee must be considered not guilty unless proven otherwise.
4) If conducted properly and without bias, the employer's decision is unlikely to be overturned even if challenged.
Pleadings are written statements submitted to assert claims and defenses. The main pleadings discussed are complaints, counterclaims, cross-claims, answers, and replies. A complaint must state the names of the plaintiff and defendant, contain a concise statement of ultimate facts, and relief prayed for. A counterclaim is a claim by the defendant against the plaintiff arising from the same transaction. It must be answered within 10 days. An answer sets forth defenses, which can be negative (specific denial) or affirmative (new matter like payment or statute of limitations). Replies respond to answers. A complaint must establish a right of the plaintiff, an obligation of the defendant, and a violation of that right. Pleadings must comply with
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Our Cyber Liability Insurance program that offers comprehensive and proactive solutions to the critical cyber data breach issues faced by business. Here is the application form for Information Security & Privacy Insurance with Breach Response Services.
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- A US patent grants the patent holder the exclusive right to make, use, sell or import an invention for 20 years from the date the patent application was filed. Infringement occurs when an unauthorized party practices the patented invention without permission.
- There are exceptions to infringement for research or experimental use, as well as uses reasonably related to developing information for FDA approval of drugs or medical devices.
- Common defenses to infringement claims include invalidity of the patent, inequitable conduct during patent prosecution, or improper inventorship. Remedies for infringement include injunctions and damages such as lost profits or reasonable royalties.
The document provides an overview of the Maryland Public Information Act (MPIA). It discusses that the MPIA provides broad public access to records held by government bodies, with specific required and permissible denials to protect privacy. It outlines the scope of the MPIA, rules for requests and responses, fees, and judicial review process for challenging denials of access. The MPIA aims to function as both an open records and privacy law for Maryland state and local governments.
What are the keys to an effective workplace investigation?CohenGrigsby
Over the past year, allegations of unlawful harassment have dominated headlines. As a result, many employers have revised their anti-harassment policies. However, a well drafted policy is meaningless unless complaints of harassment are promptly investigated and appropriate corrective action is taken.
This document outlines the Rule on the Writ of Amparo, a remedy available in the Philippines for cases involving threats or violations of a person's right to life, liberty, and security by unlawful acts of public officials or private individuals. It establishes who can file a petition for the writ, where it can be filed, required contents of the petition, procedures for serving the writ, required contents of the respondent's return, interim reliefs available, and prohibited pleadings and motions. The goal is to provide a summary hearing and determination of petitions within 7 days of the writ's issuance.
The document discusses interlocutory applications in Indian law. It begins by defining an interlocutory application as a motion for interim relief sought before a final decision in a case. It notes that interlocutory applications allow parties to seek interim orders to help their case or protect their rights. The document outlines the types of interlocutory applications, the steps to make one, and provides examples of landmark cases related to granting interim injunctions. It concludes by emphasizing the importance of interlocutory applications in keeping legal proceedings on track.
The document discusses interlocutory applications in Indian law. It begins by defining an interlocutory application as a motion for interim relief sought before a final decision in a case. It notes that interlocutory applications allow parties to seek interim orders to help their case or protect their rights. The document outlines the types of interlocutory applications, the steps to make one, and provides examples of landmark cases related to granting interim injunctions. It concludes by emphasizing the importance of interlocutory applications in keeping legal proceedings on track.
This document provides guidance on drafting effective discovery in a dissolution case. It discusses the purpose and scope of discovery under Iowa rules, including relevant and privileged matters. Discovery objectives are outlined as capturing evidence, securing admissions, identifying witnesses, and preparing for trial. Advantages and disadvantages of written interrogatories are presented. Drafting considerations include instructions to parties, defining terms, tailoring requests, identifying persons and documents, and using contention interrogatories. The overall purpose is to educate parties on their discovery obligations and reduce surprises at trial.
This presentation by Beryl A. Howell Bio, Chief Judge, United States District Court for the District of Columbia, was made during the discussion Access to the case file and protection of confidential information” held at the 130th meeting of the OECD Working Party No. 3 on Co-operation and Enforcement on 3 December 2019. More papers and presentations on the topic can be found at oe.cd/acfci.
Sample responses to form interrogatories for California divorceLegalDocsPro
These sample responses to form interrogatories for a California divorce can also be used in a legal separation or nullity case as well. They are designed to be used in responding to Judicial Council Form FL-145 Form Interrogatories-Family Law. The sample on which this preview is based is 10 pages and contains brief instructions, a verification and proof of service by mail.
Virginia Unemployment Compensation; Some Practical Procedural Tips for ClaimantsSusan Wuchinich
1) According to data from 2008, only 26% of Virginia unemployment claimants were successful, while 74% were unsuccessful. Most claimants go to hearings without proper preparation or representation.
2) It is beneficial for claimants to consult with a legal representative familiar with Virginia's unemployment system prior to the initial fact-finding interview with a deputy examiner. The representative can evaluate the claim and advise on how to present facts.
3) If a claim is initially denied, claimants should contact their representative before filing an appeal to get guidance on gathering supporting evidence for the hearing with an attorney examiner. Taking these procedural steps gives claimants the best chance to succeed in their appeal.
This document is a mutual non-disclosure agreement between Innoppl, Inc. and an individual/company to protect confidential information that may be shared as they discuss a potential business relationship. It defines confidential information, outlines the parties' obligations to maintain confidentiality and limit use of such information, and stipulates that all confidential information remains the property of the disclosing party. The agreement also specifies remedies for breach, governs by Georgia law, and remains in effect for 3 years following any disclosure or as long as trade secrets remain protected by law.
Please readRobert Geraci, Russia Minorities and Empire,” in .docxTatianaMajor22
Please read:
Robert Geraci, “Russia: Minorities and Empire,” in Abbott Gleason, ed., A Companion to Russian History (Oxford: Wiley-Blackwell, 2009), 243-260.
And discuss:
How does Geraci portray the legacy of the early Russian history for the make-up of 18-19th century Russia?
Please read: Leonard Victor Rutgers, “Roman Policy Towards the Jews: Expulsions from the City of Rome during the First Century C.E.,” in Classical Antiquity, Vol. 13, No. 1 (Apr., 1994), pp. 56-74.
And discuss: Rutgers surveys the different reasons historians have given for the expulsion of the Jews from Rome in the first century C.E. Who place did Jews have in Roman society at this time? Were they expelled because of their religious practices, or because they were ‘unruly’ as Rutgers argues? If so, what caused them to act in this way? What kind of historical evidence does the author use?
There are 2 essay, each one should write at least 300-350 words and plus one reference page.
MLA format. Must use quote( “ ”) for every source you use from website. And put (author, page number) behind quote.
Roman Policy towards the Jews: Expulsions from the City of Rome during the First Century
C.E.
Author(s): Leonard Victor Rutgers
Source: Classical Antiquity, Vol. 13, No. 1 (Apr., 1994), pp. 56-74
Published by: University of California Press
Stable URL: http://www.jstor.org/stable/25011005 .
Accessed: 26/08/2011 13:35
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University of California Press is collaborating with JSTOR to digitize, preserve and extend access to Classical
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LEONARD VICTOR RUTGERS
Roman Policy towards the Jews:
Expulsions from the City of Rome
during the First Century c. E.
Tant de causes secretes se melent souvent a la cause apparente, tant de ressorts
inconnus servent a persecuter un homme, qu'il est impossible de demeler dans les
siecles posterieures la source cachee des malheurs des hommes les plus consider
ables, a plus forte raison celle du supplice d'un particulier qui ne pouvait etre
connu que par ceux de son parti.
-Voltaire, Traite sur la tolerance (1763)
IN THIS ARTICLE I want to discuss the evidence for expulsions of Jews from
the city of Rome in the first century C.E. Scholars have long been interested in the
reasons underlying these expulsions. Because the anci.
Ford VS ChevroletThere are many reasons that make the Chevy.docxTatianaMajor22
Ford VS Chevrolet
There are many reasons that make the Chevy’s and Ford’s motors two most common trucks. Studies reveal that that they are the most popular vehicles on sales today. It is because they are powerful, versatile and reasonably priced. They also come in a wide variety of configurations and styles. However, many buyers and sellers have questioned themselves on the better vehicle compared to the other in terms of quality, Wi-Fi, price ranges, value, and costs. To compare and contrast on this subject, let us take an example of two vehicles each from each company to facilitate comparison.
Ford offers the full-size track with automatic high-beam control, automatic parallel parking and power-retractable running boards. Fords are elegant, and they are mostly aluminum making them save weight and bolster gas mileage. None of these features are offered Chevy’s. Chevrolets have outstanding quality. They are mostly comprised of steel, for instance, the Chevrolet Silverado. This makes them good for rough roads and difficult terrains.
Fords have employed the use of up to date Wi-Fi technology. Ford intends to provide the Ford Sync, which will provide robust connections for occupants. Latest Chevrolet brands Malibu utilize the 4G LTE Wi-Fi Technology that provides rich in-vehicle experiences. This technology is powerful compared to Ford Sync, and is used for connecting devices and executing few remote operations within the car.
From the value and cost standpoint, Ford can consume a little more, and its payload capacity is a little higher. Additionally, its mileage is too better. The prices vary from nation to nation. Chevrolet seems to be a little cheaper, and reasonably priced going for $33,044, which is slightly less than Ford, but the differences are not serious to propel buyers towards one truck leaving the other
Technophiles are likely to put their preferences on Ford to Chevrolet. On overall, Fords have many features as compared Chevy’s. However, they may be hard to maintain. Compared to Fords, Chevrolets are reliable and cheaper. However, the two brands are equally good performers. It is, therefore, prudent to pick what one thinks would fit his or her usage and preference and personal style
Ethical Systems, Research Paper, Spring 2015, Douglas Green, Page 1 of 1
Ethical
Systems/Final
Research
Paper
2,000
words
minimum,
double-‐spaced
Final
Draft
Due:
Tuesday,
April
28,
12:00
pm
(afternoon)
Please
email
your
final
research
paper
to
me
via
MS
Word
attachment
AND
by
cutting/pasting
the
entire
document
into
the
body
of
your
email.
IF
YOU
DO
NOT
RECEIVE
A
CONFIRMATION
EMAIL
BACK,
I
DID
NOT
RECEIVE
YOUR
ESSAY
AND
YOU
WILL
LOSE
ALL
CREDIT
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REQUIREMENT.
NO
LATE
WORK
WILL
BE
ACCEPTED…
PERIOD!
.
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Please readRobert Geraci, Russia Minorities and Empire,” in .docxTatianaMajor22
Please read:
Robert Geraci, “Russia: Minorities and Empire,” in Abbott Gleason, ed., A Companion to Russian History (Oxford: Wiley-Blackwell, 2009), 243-260.
And discuss:
How does Geraci portray the legacy of the early Russian history for the make-up of 18-19th century Russia?
Please read: Leonard Victor Rutgers, “Roman Policy Towards the Jews: Expulsions from the City of Rome during the First Century C.E.,” in Classical Antiquity, Vol. 13, No. 1 (Apr., 1994), pp. 56-74.
And discuss: Rutgers surveys the different reasons historians have given for the expulsion of the Jews from Rome in the first century C.E. Who place did Jews have in Roman society at this time? Were they expelled because of their religious practices, or because they were ‘unruly’ as Rutgers argues? If so, what caused them to act in this way? What kind of historical evidence does the author use?
There are 2 essay, each one should write at least 300-350 words and plus one reference page.
MLA format. Must use quote( “ ”) for every source you use from website. And put (author, page number) behind quote.
Roman Policy towards the Jews: Expulsions from the City of Rome during the First Century
C.E.
Author(s): Leonard Victor Rutgers
Source: Classical Antiquity, Vol. 13, No. 1 (Apr., 1994), pp. 56-74
Published by: University of California Press
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LEONARD VICTOR RUTGERS
Roman Policy towards the Jews:
Expulsions from the City of Rome
during the First Century c. E.
Tant de causes secretes se melent souvent a la cause apparente, tant de ressorts
inconnus servent a persecuter un homme, qu'il est impossible de demeler dans les
siecles posterieures la source cachee des malheurs des hommes les plus consider
ables, a plus forte raison celle du supplice d'un particulier qui ne pouvait etre
connu que par ceux de son parti.
-Voltaire, Traite sur la tolerance (1763)
IN THIS ARTICLE I want to discuss the evidence for expulsions of Jews from
the city of Rome in the first century C.E. Scholars have long been interested in the
reasons underlying these expulsions. Because the anci.
Ford VS ChevroletThere are many reasons that make the Chevy.docxTatianaMajor22
Ford VS Chevrolet
There are many reasons that make the Chevy’s and Ford’s motors two most common trucks. Studies reveal that that they are the most popular vehicles on sales today. It is because they are powerful, versatile and reasonably priced. They also come in a wide variety of configurations and styles. However, many buyers and sellers have questioned themselves on the better vehicle compared to the other in terms of quality, Wi-Fi, price ranges, value, and costs. To compare and contrast on this subject, let us take an example of two vehicles each from each company to facilitate comparison.
Ford offers the full-size track with automatic high-beam control, automatic parallel parking and power-retractable running boards. Fords are elegant, and they are mostly aluminum making them save weight and bolster gas mileage. None of these features are offered Chevy’s. Chevrolets have outstanding quality. They are mostly comprised of steel, for instance, the Chevrolet Silverado. This makes them good for rough roads and difficult terrains.
Fords have employed the use of up to date Wi-Fi technology. Ford intends to provide the Ford Sync, which will provide robust connections for occupants. Latest Chevrolet brands Malibu utilize the 4G LTE Wi-Fi Technology that provides rich in-vehicle experiences. This technology is powerful compared to Ford Sync, and is used for connecting devices and executing few remote operations within the car.
From the value and cost standpoint, Ford can consume a little more, and its payload capacity is a little higher. Additionally, its mileage is too better. The prices vary from nation to nation. Chevrolet seems to be a little cheaper, and reasonably priced going for $33,044, which is slightly less than Ford, but the differences are not serious to propel buyers towards one truck leaving the other
Technophiles are likely to put their preferences on Ford to Chevrolet. On overall, Fords have many features as compared Chevy’s. However, they may be hard to maintain. Compared to Fords, Chevrolets are reliable and cheaper. However, the two brands are equally good performers. It is, therefore, prudent to pick what one thinks would fit his or her usage and preference and personal style
Ethical Systems, Research Paper, Spring 2015, Douglas Green, Page 1 of 1
Ethical
Systems/Final
Research
Paper
2,000
words
minimum,
double-‐spaced
Final
Draft
Due:
Tuesday,
April
28,
12:00
pm
(afternoon)
Please
email
your
final
research
paper
to
me
via
MS
Word
attachment
AND
by
cutting/pasting
the
entire
document
into
the
body
of
your
email.
IF
YOU
DO
NOT
RECEIVE
A
CONFIRMATION
EMAIL
BACK,
I
DID
NOT
RECEIVE
YOUR
ESSAY
AND
YOU
WILL
LOSE
ALL
CREDIT
FOR
THIS
REQUIREMENT.
NO
LATE
WORK
WILL
BE
ACCEPTED…
PERIOD!
.
Fairness and Discipline Weve all been disciplined at one.docxTatianaMajor22
Fairness and Discipline
We've all been disciplined at one time or another by a parent or a teacher. What disciplinary experiences have you had as a child that took a non-punitive approach?
I need paragraph or half page with reference
.
Appendix 12A Statement of Cash Flows—Direct MethodLEARNING .docxTatianaMajor22
Appendix 12A
Statement of Cash Flows—Direct Method
LEARNING OBJECTIVE
6
Prepare a statement of cash flows using the direct method.
To explain and illustrate the direct method, we will use the transactions of Computer Services Company for 2014, to prepare a statement of cash flows. Illustration 12A-1 presents information related to 2014 for Computer Services Company.
To prepare a statement of cash flows under the direct approach, we will apply the three steps outlined in Illustration 12-4.
Illustration 12A-1
Comparative balance sheets, income statement, and additional information for Computer Services Company
STEP 1: OPERATING ACTIVITIES
DETERMINE NET CASH PROVIDED/USED BY OPERATING ACTIVITIES BY CONVERTING NET INCOME FROM AN ACCRUAL BASIS TO A CASH BASIS
Under the direct method, companies compute net cash provided by operating activities by adjusting each item in the income statement from the accrual basis to the cash basis. To simplify and condense the operating activities section, companies report only major classes of operating cash receipts and cash payments. For these major classes, the difference between cash receipts and cash payments is the net cash provided by operating activities. These relationships are as shown in Illustration 12A-2.
Illustration 12A-2
Major classes of cash receipts and payments
An efficient way to apply the direct method is to analyze the items reported in the income statement in the order in which they are listed. We then determine cash receipts and cash payments related to these revenues and expenses. The following pages present the adjustments required to prepare a statement of cash flows for Computer Services Company using the direct approach.
CASH RECEIPTS FROM CUSTOMERS.
The income statement for Computer Services Company reported sales revenue from customers of $507,000. How much of that was cash receipts? To answer that, companies need to consider the change in accounts receivable during the year. When accounts receivable increase during the year, revenues on an accrual basis are higher than cash receipts from customers. Operations led to revenues, but not all of these revenues resulted in cash receipts.
To determine the amount of cash receipts, the company deducts from sales revenue the increase in accounts receivable. On the other hand, there may be a decrease in accounts receivable. That would occur if cash receipts from customers exceeded sales revenue. In that case, the company adds to sales revenue the decrease in accounts receivable. For Computer Services Company, accounts receivable decreased $10,000. Thus, cash receipts from customers were $517,000, computed as shown in Illustration 12A-3.
Illustration 12A-3
Computation of cash receipts from customers
Computer Services can also determine cash receipts from customers from an analysis of the Accounts Receivable account, as shown in Illustration 12A-4.
Illustration 12A-4
Analysis of Accounts Receivable
Illustration.
Effects of StressProvide a 1-page description of a stressful .docxTatianaMajor22
Effects of Stress
Provide a 1-page description of a stressful event currently occurring in your life.
Discuss I am married work a full time job as an occupational therapy assistant am taking two courses
Have to take care of a home feed the animals attend to laundry
Think of my pateitns worry about their well being and what I can do for them ( I bring home my patients issues)
Constantly doing paper work for work such as documentation for billing
I feel like I have no free time for me some days I don’t even eat dinner or lunch because I don’t have time to make anything or am just too tired to cook
On top of this I am married and married ppl do argue and my husband am I have been bunting heads on finances.
Then, referring to information you learned throughout this course, address the following:
· What physiological changes occur in the brain due to the stress response?
· What emotional and cognitive effects might occur due to this stressful situation?
· Would the above changes (physiological, cognitive, or emotional) be any different if the same stress were being experienced by a person of the opposite sex or someone much older or younger than you?
· If the situation continues, how might your physical health be affected?
· What three behavioral strategies would you implement to reduce the effects of this stressor? Describe each strategy. Explain how each behavior could cause changes in brain physiology (e.g., exercise can raise serotonin levels).
· If you were encouraging an adult client to make the above changes, what ethical considerations would you have to keep in mind? How would you address those ethical considerations?
In addition to citing the online course and the text, you are also required to cite a minimum of four scholarly sources. For reputable web sources, look for .gov or .edu sites as opposed to .com sites. Please do not use Wikipedia.
Your paper should be double-spaced, in 12-point Times New Roman font, and with normal 1-inch margins; written in APA style; and free of typographical and grammatical errors. It should include a title page with a running head, an abstract, and a reference page.
The body of the paper should be at least 6 pages in length total
not including the reference or title page
Assignment 1 Grading Criteria
Maximum Points
Described a stressful event.
20
Explained the physiological changes that occur in the brain due to the stress response.
36
Explained the emotional and cognitive effects that may occur due to this stressful situation.
32
Analyzed potential differences in physiological, cognitive, and emotional responses in someone of a different age or sex.
32
Discussed the physical health risks.
28
Provided three behavioral strategies to reduce the effects of the stressor and explained how each could cause changes in brain physiology.
40
Analyzed ethical considerations in implementing behavioral strategies and offered suggestions for addressing these.
40
Integrated at least two scholarly references .
Design Factors NotesCIO’s Office 5 People IT Chief’s Offi.docxTatianaMajor22
Design Factors
Notes
CIO’s Office
5 People
IT Chief’s Office
5 People
LAN/WAN Maint.
20 People
Reception
4 People
Telecommunications
20 People
LAN Management
50 People
Server Room A
2 Person
Server Room B
4 Person
Equipment:
Patch Cable
Computer to Wall
Patch Cable
LAN Room
Cable Trays/Runs
Horizontal Runs
Cisco Border Router
Research: Attached to 5 Floor Switches
Server Room A
10 Servers
Server Room B
10 Servers
Computers
One Per Person
Standard floor (first floor) Lesson 2 Project Plan info
Design Factors
Notes
CIO’s Office
5 People
IT Chief’s Office
5 People
LAN/WAN Maint.
20 People
Reception
4 People
Telecommunications
20 People
LAN Management
50 People
Server Room A
2 Person
Server Room B
4 Person
Equipment:
Patch Cable
Computer to Wall
Patch Cable
LAN Room
Cable Trays/Runs
Horizontal Runs
Cisco Border Router
Research: Attached to 5 Floor Switches
Server Room A
10 Servers
Server Room B
10 Servers
Computers
One Per Person
Basement floor
Design Factors
Notes
Vertical Riser Run
On Outside Wall of LAN Room on Each Floor.
Fiber-Optic Multimode
Riser Runs: Backbone
SC Connectors
Fiber-Optic Cable
Cisco Catalyst: Switch: WS-C3750G-24PS-S: 24 Ports
Leave a Minimum of four ports free on each switch
Color Laser Printer
Minimum of One per Room or One per 20 people
Vertical Riser Run
On Outside Wall of LAN Room on Each Floor and Server RM B on this floor.
Fiber-Optic Multimode
Riser Runs: Backbone
SC Connectors
Fiber-Optic Cable
Cable Trays/Runs
Horizontal Runs
Horizontal Runs
Leave a Minimum of four ports free on each switch
Applicataion
U.S. Minimum Requirement Ranges
Space per Employee - 1997
Two people, such as a supervisor and an employee, can meet in an office with a table or desk between them
60" to 72" x 90" to 126:/5.78m2 to 11.7m2
280Sq. Ft./26.0m2
Worker has a primary desk plus a return
60" to 72"x60"to 84"/5.78 to 7.8m2
193Sq. Ft./17.9m2
Executive office - three to four people can meet around a desk
105 to 130"x96 to 123"/9.75 to 11.4 m2
142Sq. Ft./13.2m2
Basic workstation such as a call center
42" to 52" x 60" to 72"/3.9 to 6.7 m2
114Sq. Ft./10.6 m2
NT1310: Project
Page 1
PRO JECT D ESC RIPT ION
As the project manager for the Cable Planning team, you will manage the creation of the cable plan for
the new building that will be built, with construction set to begin in six weeks.
The deliverables for the entire Cable Plan will consist of an Executive Summary, a PowerPoint
Presentation and an Excel Spreadsheet. You will develop different parts of each of these in three parts.
The final organization should contain these elements:
The Executive Summary:
o Project Introduction
o Standards and Codes
Cable Standards and Codes
Building Standards and Codes
o Project Materials
o Copper Cable, Tools, and Test Equipment
o Fiber-Optic Cable, Tools, and Test Equipment
o Fiber-Optic Design Considerations
o Basement Server Comp.
Question 12.5 pointsSaveThe OSU studies concluded that le.docxTatianaMajor22
The document contains questions about leadership, motivation, communication, groups/teams, and decision making. The questions assess knowledge of topics like situational leadership theory, Maslow's hierarchy of needs, organizational communication barriers, stages of team development, and group decision making techniques like brainstorming.
Case Study 1 Questions1. What is the allocated budget .docxTatianaMajor22
Case Study 1 Questions:
1. What is the allocated budget ? $250,000
2. Where does the server room located? Currently, there is no server room
3. What is the number of users with PCs inside each existing site?
Currently there are
4. What is the current cabling used in each location? (cat5e or cat6) Current cabling does not meet the company’s current and future needs
5. Do want us to upgrade token Ring or use a completely new Ethernet network What is your recommendation and why?
6. regarding the ordering system , it is not clear what the we should do , do you want to talk about how to connect the system to the network or how to built the ordering online system because it is more software engineering than networking . Talk about the kind of network (hardware) you recommend based on the business requirements
7. all the sites should have access to our servers in the main branch? yes
8. Regarding the order software, do you need more details about the way it works or just about its connection with the network? Your solution should be from a network point of view
9. Distances are given in Meters or feet? feet
10. Shipment is done by truck, or ships? Currently, only trucking
11. In Dimebox branch, where are administration offices located? See Business goals # 4
12. What is the current network connectivity status? How many devices are currently on the network? How they are physically laid out? Is cabling running all over the floor, hidden in walls or threaded through the ceiling? What are the switches used and its speed? Currently, only the office is networked (token ring) NOVELL
13. What is the minimum Internet speed wanted? See Business Goals on page 2 – I only can tell you what we need the network for, you must tell me what we need to meet the business needs
14. Will the corporation provide wireless access? If yes will it be in all department and buildings? Wireless access would be helpful if we can justify the cost
15. Are there phones in offices? yes
16. What is the internet speed available now? What speed do you want for future? Internet access is through time warner cable company which is not very reliable
17. Do employees access their emails outside the company? yes
18. Do you have plans for future expansion? We like to increase our customer base by 20% over the next year
REMEMBER, you are the IT expert, I’m only a business person who must rely on your expertise.
Network Design and Performance
Case Study
Dooma-Flochies, Inc. with headquarters located on Podunk Road in Trumansburg, NY, is the sole manufacturer of Dooma-Flochies (big surprise). They currently have a manufacturing facility in, Lake Ridge, NY (across Cayuga Lake) on Cayuga Dr. and have recently diversified by purchasing a company, This-N-That, on Industry Ave. in, Dime Box Texas. This-N-That is the sole competitor of Domma-Flochies with their product Thinga-Ma-Jigs. This acquisition gives Dooma-Flochies, Inc a monopoly in this mark.
Behavior in OrganizationsIntercultural Communications Exercise .docxTatianaMajor22
Behavior in Organizations
Intercultural Communications Exercise Response Paper –
Week 5
The most overt cultural differences, such as greeting rituals and name format, can be overcome most easily. The underlying, intangible differences are very difficult to overcome. In this case, the underlying cultural differences are
· Assumptions about the purpose of the event (is the party strictly for fun and for relationship building, or are their business matters to take care of?).
· Assumptions about the purpose and the nature of business relationship.
· Assumptions about power and leadership relationships (who makes the decisions and how?).
· Response styles (verbal and nonverbal signals of agreement, disagreement, politeness, etc.).
Many (though not all) cultural differences can be overcome if you carefully observe other people, think creatively, remain flexible, and remember that your own culture is not inherently superior to others.
The Scenario
Three corporations are planning a joint venture to sponsor an international concert tour. The corporations are Decibel, an agency representing the musicians (from the US, Britain, and Japan); Images, a marketing firm which will handle sales of tickets, snacks and beverages, clothing, and CDs; and Event, a special events company which will hire the ushers, concessionaires, and security officers; print the programs; and clean up the arenas after the shows. The companies come from three different cultures: Blue, Green, and Red. Each has specific cultural traits, customs, and practices.
You are a manager in one of these companies. You will attend the opening cocktail party in Perth, Australia the evening before a 3-day meeting during which the three companies will negotiate the details of the partnership. Your management team includes a Vice President and a number of other managers.
During the 3-day meeting, the companies have the following goals:
Decibel
· As high a royalty rate as possible on sales of T-shirts, videos, and CDs
· Aggressive marketing and advertising to increase attendance and sales
· Good security, both before and during the show Image
Image
· Well known bands that will be easy to market
· As much income as possible from the concerts
· Smoothly functioning event so that publicity from early concerts is positive
Event
· Bands that are not likely to provoke stampedes, riots, or other antisocial behavior
· Bands that are reliable and will show up on time, ready to play
· As much income as possible from the concerts
The cultures that are assigned to the various companies are:
BLUE CULTURE
Image (Marketing Company)
Beliefs, Values, and Attitudes that Underlie This Culture’s Communication
Believe that fate and luck control most things.
Believe in feelings more than reasoning.
An authoritarian leader makes the ultimate decisions.
Nonverbal Traits of This Culture
Treat time as something that is unimportant. It is not a commodity that can be lost.
Conversation distance is close (about 15 inches, face-.
Discussion Question Comparison of Theories on Anxiety Disord.docxTatianaMajor22
Discussion Question:
Comparison of Theories on Anxiety Disorders
There are numerous theories that attempt to explain the development and manifestation of psychological disorders. Some researchers hold that certain disorders result from learned behaviors (behavioral theory), while other researchers believe that there is a genetic or biological basis to psychological disorders (medical model), while still others hold that psychological disorders stem from unresolved unconscious conflict (psychoanalytic theory). How would each of these theoretical viewpoints explain anxiety disorders? Does one explain the development and manifestation of anxiety disorders better than the others?
200- 400 words please
Three min resources with
in text citations and examples
you can use the following as a module reference
cite as university 2014
Anxiety Disorders
Anxiety disorders such as panic disorder, specific phobias, and social anxiety disorder feature a heightened autonomic nervous system response that is above and beyond what would be considered normal when faced with the object or situation that the person reacts to. For example, a person with a specific phobia of spiders (called arachnophobia) experiences a heightened autonomic response when confronted with a spider (or even an image of a spider). This anxiety response must result in significant distress or impairment. In general, anxiety disorders have been linked to underactive gamma-aminobutyric acid (GABA) in the brain, resulting in overexcitability of the amygdala and the anterior cingulate cortex. Additionally, genetic research shows that anxiety disorders demonstrate a clear pattern of genetic predisposition
Charles Darwin's Perspective
We talked about Charles Darwin when discussing evolution and natural selection. Darwin was also very interested in emotions. One of his books published in 1872,The Expression of Emotions in Man and Animals, was devoted to this topic.
Darwin believed that emotions play an important role in the survival of the species and result from evolutionary processes in the same way as other behaviors and psychological functions. Darwin's writing on this topic also prompted psychologists to study animal behavior as a way to better understand human behavior.
James–Lange Theory of Emotions
Modern theories of emotion can be traced to William James and Carl Lange (Pinel, 2011). William James was a renowned Harvard psychologist who is sometimes called the father of American psychology. Carl Lange was a Danish physician. James and Lange formulated the same theory of emotions independently at about the same time (1884). As a result, it is called the James–Lange theory of emotions. This theory reversed the commonsensical notion that emotions are automatic responses to events around us. Instead, it proposes that emotions are the brain's interpretation of physiological responses to emotionally provocative stimuli.
Cannon–Bard Theory of Emotions
In 1915, Harvard physiologist Walt.
I have always liked Dustin Hoffmans style of acting, in this mov.docxTatianaMajor22
I have always liked Dustin Hoffman's style of acting, in this movie he takes on a sexually deprived young male just out of college, and has never been with a female, and is duped by horny older woman that feels neglected. Dustin Hoffman takes the characters form of a young male, goofy, respectful virgin and intelligent male, missing something but not really sure at the beginning till Ann Bancroft coaxes him with seduction to fulfill her own needs. In an other movie called "The life of Little Big Man" he plays almost the same character but as a white child raised by the Native Americans and a wise old chief that deeply care and loves him as his own, and Fay Dunaway plays a Holy rollers wife that is older and sexually deprived and feeling neglected by her husband and also she goes through major changes in her life from devoted wife, to a honey bell/ house hooker, whats funny Dustin Hoffman is a awesome actor but has to have his surrounding characters bring his character to life. The Graduate was Dustin Hoffman's first big movie of his career.
I actually liked movie "Little Big man" way better due to he went through major changes in his life, from being a Native boy warrior, captured by Yankees, meets Fay Dunaway who loves to give baths, to finding his sister who teaches him to be a gunslinger and then returns to his Grand Father to be a native again and tells his blind Grand Father the world of the white man is a crazy one, then his see the Psyho Col. Custer and gets his revenge by telling Custer the truth. The movie Little Big Man makes you laugh, teaches you things about people and survial and cry at times... its a must see...
Although a stray away from the Benjamin Braddock written about in the novel The Graduate, Dustin Hoffman does an awesome job with this character on film. When you first meet Ben he is at a party that his parents are throwing in his academic honor upon his graduation from school and return home. The whole night, Hoffman stumbles though various conversations and tries to coyly escape from the festivities. Small things such as this Hoffman did a great job at, conveying the hesitance and crisis that Ben was going through as a graduate. There are multiple times in the movie he hardly expresses anything at all, yet it clearly shows you that Ben is having a very hard time internally with everything going on. Even through his relationships with Mrs. Robinson and her daughter Elaine you see the young man struggling with himself through either failed attempts at affection or lack thereof.
.
Is obedience to the law sufficient to ensure ethical behavior Wh.docxTatianaMajor22
Is obedience to the law sufficient to ensure ethical behavior? Why, or why not? Support your answer with at least three reasons that justify your position.
100 words
Discuss the differences between an attitude and a behavior. Provide 4 substantive reasons why it is important for organizations to monitor and mitigate employee behavior that is either beneficial or detrimental to the organization's goals and existence.
150 words
.
If you are using the Blackboard Mobile Learn IOS App, please clic.docxTatianaMajor22
If you are using the Blackboard Mobile Learn IOS App, please click "View in Browser." V BUS 520Week 9 Assignment 4 Paper
I need the paper as soon as possible
Students, please view the "Submit a Clickable Rubric Assignment" in the Student Center.
Instructors, training on how to grade is within the Instructor Center.
Assignment 4: Leadership Style: What Do People Do When They Are Leading?
Due Week 9 and worth 100 points
Choose one (1) of the following CEOs for this assignment: Larry Page (Google), Tony Hsieh (Zappos), Gary Kelly (Southwest Airlines), Meg Whitman (Hewlett Packard), Ursula Burns (Xerox), Terri Kelly (W.L. Gore), Ellen Kullman (DuPont), or Bob McDonald (Procter & Gamble). Use the Internet to investigate the leadership style and effectiveness of the selected CEO. (Note: Just choose one that is easier for you to right about.) It does not matter to me which CEO you pick
Write a five to six (5-6) page paper in which you:
1. Provide a brief (one [1] paragraph) background of the CEO.
2. Analyze the CEO’s leadership style and philosophy, and how the CEO’s leadership style aligns with the culture.
3. Examine the CEO’s personal and organizational values.
4. Evaluate how the values of the CEO are likely to influence ethical behavior within the organization.
5. Determine the CEO’s three (3) greatest strengths and three (3) greatest weaknesses.
6. Select the quality that you believe contributes most to this leader’s success. Support your reasoning.
7. Assess how communication and collaboration, and power and politics influence group (i.e., the organization’s) dynamics.
8. Use at least five (5) quality academic resources in this assignment. Note: Wikipedia and other Websites do not qualify as academic resources.
Your assignment must follow these formatting requirements:
· Be typed, double spaced, using Times New Roman font (size 12), with one-inch margins on all sides; citations and references must follow APA or school-specific format. Check with your professor for any additional instructions.
· Include a cover page containing the title of the assignment, the student’s name, the professor’s name, the course title, and the date. The cover page and the reference page are not included in the required assignment page length.
The specific course learning outcomes associated with this assignment are:
· Analyze the formation and dynamics of group behavior and work teams, including the application of power in groups.
· Outline various individual and group decision-making processes and key factors affecting these processes.
· Examine the primary conflict levels within organization and the process for negotiating resolutions.
· Examine how power and influence empower and affect office politics, political interpretations, and political behavior.
· Use technology and information resources to research issues in organizational behavior.
· Write clearly and concisely about organizational behavior using proper writing mechanics.
Click here.
Is the proliferation of social media and communication devices a .docxTatianaMajor22
Social media and communication devices have both benefits and drawbacks for society. While they allow easy connection with others and access to information, overuse can negatively impact relationships and mental health. Overall, moderation is key to reap the upsides of technology while avoiding the downsides.
MATH 107 FINAL EXAMINATIONMULTIPLE CHOICE1. Deter.docxTatianaMajor22
The document contains a 30-question math exam covering topics like functions, graphs, equations, inequalities, logarithms, and other math concepts. It includes multiple choice, short answer, and show work questions assessing skills like domain and range, solving equations, graphing, composites, inverses, lines, maximizing profit, and more. Students must demonstrate mathematical reasoning and problem-solving abilities.
If the CIO is to be valued as a strategic actor, how can he bring.docxTatianaMajor22
If the CIO is to be valued as a strategic actor, how can he bring to the table the ethos of alignment, bound to the demands of process strategic planning to move IT to the forefront of the organization's future? Is there a lack of information on strategic planning? Nope. I think the process of planning is poorly understood, and rarely endorsed. The reasons are simple enough. Planning requires a commitment of resources (time, talent, money); it requires insight; it requires a total immersion in the corporate culture. While organizations do plan, planning is invariably attached to the budget process. It is typically here that the CIO lays out his/her vision for the coming year Now a few years ago authors began writing on the value of aligning IT purpose to organizational purpose. They wrote at a time when enterprise architectural planning was fairly new, and enterprise resource management was on the lips of every executive. My view is that alignment is a natural process driven by the availability of the tools to accomplish it. Twenty years ago making sense of IT was more about processing power, and database management. We are in a new age of IT, and it is the computer that is the network, not the network as an independent self-contained exchange of information. If you will spend some time reviewing the basic materials I provided on strategic planning and alignment, we can begin our discussions for the course. Again, here is the problem I would like for us to tackle: If the CIO is to be valued as a strategic actor, how can he bring to the table the ethos of alignment, bound to the demands of process strategic planning to move IT to the forefront of the organization's future? Most of the articles I bundled together for this week are replete with tables and charts. These can be a heavy read. Your approach should be to review these articles for the "big ideas" or lessons that are take away. I think these studies are significant enough that we will conclude our first week with an understanding of the roles between executive leaders, and how they see Information Technology playing a role in shaping a business strategy.
Read the articles to answer the question. Please No Plagerism or verbatim but you are allowed to quote from the article.
Achieving and Sustaining
Business-IT Alignment
Jerry Luftman
Tom Brier
I
n recent decades, billions of dollars have been invested in intormation tech-
nology (IT). A key concern of business executives is alignment—applying IT
in an appropriate and timely way and in harmony with business strategies,
goals, and needs. This issue addresses both how IT is aligned with the busi-
ness and how the business should be aligned with IT Frustratingly, organizations
seem to find it difficult or impossible to harness the power of information tech-
nology for their own long-term benefit, even though there is worldwide evi-
dence that IT has the power to transform whole industries and markets.' How
can companies.
I am showing below the proof of breakeven, which is fixed costs .docxTatianaMajor22
I am showing below the proof of breakeven, which is fixed costs/ contribution margin.
We start with the definition of breakeven and proceed using elementary algebra to derive the formula. Breakeven is a number and is created by knowing fixed and variable costs, and the retail sales price. It is thus not a point of discussion but is based on the assumptions of these variables.
Proof of Breakeven
Definition of BreakevenVolume: Total Revenue = Total Expenses
Definition
1.Total Revenue = Total Expenses
Breakdown of Definition
2. Retail Price * Volume = Fixed Expenses + Variable Expenses
Further Analysis
3. Retail Price * Volume = Fixed Expenses + (Volume * Unit Variable Expenses)
Subtract (Volume * Unit Variable Expenses) from both sides
4. Fixed Expenses = (Retail Price * Volume) — (Volume * Unit Variable Expenses)
Factor
5. Fixed Expenses = Volume * (Retail Price – Unit Variable Expenses)
Divide both sides by (Retail Price – Unit Variable Expenses)
6. Volume = Fixed Expenses
(Retail Price – Unit Variable Expenses)
Substitution based on Definition
7. Since (Retail Price — Unit Variable Expenses) is called Contribution Margin,
Therefore:
Breakeven Volume = Fixed Expenses / Contribution Margin
NAME_________________________________________________ DATE ____________
1. Explain some of the economic, social, and political considerations involved in changing the tax law.
2. Explain the difference between a Partnership, a Limited Liability Partnership (LLP) and a Limited Liability Company (LLC). In each structure who has liability?
3. How is “control” defined for purposes of Section 351 of the IRS Code?
4. What are the advantages and disadvantages of using debt in a firm’s capital structure?
5. Under what circumstances is a corporation’s assumption of liabilities considered boot in a Section 351exchange?
6. What are the tax consequences for the transferor and transferee when property is transferred to a newly created corporation in an exchange qualifying as nontaxable under Section 351?
7. Why are corporations allowed a dividend-received deduction? What dividends qualify for this special deduction?
8. Provide 3 examples of a Constructive Dividend. Are these Constructive Dividends taxable?
9. Discuss the tax consequences of a new Partnership Formation and give details to gain and losses and basis?
10. Provide 2 similarities and 2 differences when comparing Sections 351 and 721 of the IRS Code.
11. What is the difference between inside and outside basis with a partnership?
12. ABC Partnership distributes $12,000 of taxable income to partner Bob and $24,000 of tax-exempt income to Partner Bob. As a result of these two distributions, how does Bob’s basis change?
13. On January 1, Katie pays $2,000 for a 10% capital, profits, and loss interest in a partnership.
Examine the way in which death and dying are viewed at different .docxTatianaMajor22
Examine the way in which death and dying are viewed at different points in human development.
Using only my text as a reference:
Berger, K.S. (2011). The developing person through the life span (8th ed.).
I need 3 detailed PowerPoint slide with very detailed speaker notes. There must be detailed speaker notes on each slide. The 4th slide will be the reference.
.
Karimi 1 Big Picture Blog Post First Draft College .docxTatianaMajor22
Karimi 1
Big Picture Blog Post First Draft
College Girls in Media
Sogand Karimi
Media and Hollywood movies have affected and influenced society’s perception on
female college students. Due to Hollywood movies and media, society mostly recognizes the
negative stereotypes of a college women. Saran Donahoo, an associate professor and education
administration of Southern Illinois University, once said, “The messages in these films
consistently emphasized college as a place where young women come to have fun, engage in
romances with young men, experiment with sex and alcohol, face dilemmas regarding body
image, and encounter difficulties in associating with other college women.” In this essay I will
be talking about the recurring stereotypes and themes portrayed in three hollywood movies,
Spring Breakers, The house bunny and Legally Blond and how these stereotypes affect our
society.
The movie Spring Breakers is about four college girls who are bored with their daily
routines and want to escape on a spring break vacation to Florida. After realizing they don’t have
enough money, they rub a local diner with fake guns and ski masks. They break the laws in order
to get down to Florida, just to break more rules and laws once they’re there. During the film, you
will notice a lot of partying, drugs and sexual activity. The four girls wear bikinis for majority of
the film and are overly sexual. These are some common themes and stereotypes seen in all three
movies. Media and movies like spring breakers have made it a norm to constantly want to party,
get drunk and have sex as a college woman. In an article by Heather Long, she mentions how the
movie can even be seen as supporting rape culture. She believes because of these stereotypes
always being shown in media, it is contributing to the “girls asking for it” excuse when it comes
to rape cases with young girls. Long also said “...never mind the fact that thousands of college
students are spending their spring break not on a beach, but volunteering with groups like Habitat
for Humanity and the United Way, especially after Hurricanes Katrina and Sandy.” THIS shows
how media only displays one side of a certain group or story. Even though not all college girls
like to party and lay on a beach naked for spring break, that’s what media likes to portray. Not
only does this give the wrong message to our society but it influences bigger issues like rape, as
the author mentioned.
http://www.huffingtonpost.com/2010/03/10/alternative-spring-break_n_494028.html
http://www.huffingtonpost.com/2010/03/10/alternative-spring-break_n_494028.html
Karimi 2
The movie House bunny. The House bunny is a movie about an ex playmate or girlfriend
if Hugh Hefner that gets kicked out of the Playboy Mansion due to her aging. She then becomes
a mother of an unpopular sorority with girls that are bit geeky, and unusual compared to other
girls on campus. The story.
Please try not to use hard words Thank youWeek 3Individual.docxTatianaMajor22
Please try not to use hard words Thank you
Week 3
Individual
Problems and Goals Case Study
Select one of the following three case studies in Ch. 6 of The Helping Process:
· Case Susanna
· Case James and Samantha
· Case Alicia and Montford
Identify three to five problems in the case study you have selected.
Write a 500- to 700-word paperthatincludes the following:
· A problem-solving strategy and a goal for each problem
· The services, resources, and supports the client may need and why
· A description of how goals are measurable and realistically attainable for the client
Here is the case studies
Exercise 3: Careful Assessment
The following case studies are about Susanna, James, Samantha, Alicia, and Montford, all
homeless children attending school. The principal of the school has asked you to conduct
an assessment of these children and provide initial recommendations.
Before you begin this exercise, go to the website that accompanies this book: www.
wadsworth.com/counseling/mcclam, Chapter Three, Link 1, to read more about homeless
families and children.
Susanna
Susanna is 15 years old. Th e city where she lives has four schools: two elementary, one
middle, and one high school. Th ere are about 1,500 students enrolled in the city/county
school district and about 450 in the local high school that Susanna is attending. For the
past six months, Susanna has been living with her boyfriend and his parents. Prior to this,
she left her mother’s home and lived on the streets. She is pregnant and her boyfriend’s
parents want her to move out of their home. Her father lives in a town with his girlfriend,
about 50 miles from the city. Her mother lives outside the city with Susanna’s baby brother.
Right now Susanna’s mother is receiving child support for the two children. Susanna wants
to have a portion of the child support so that she can find a place of her own to live. Her
mother says that the only way that Susanna can have access to that money is to move back
home. Susanna refuses to move back in with her mother.
You receive a call from the behavior specialist at Susanna’s high school. Susanna’s
mother is at the school demanding that Susanna be withdrawn from school. Susanna’s
mother indicates that Susanna will be moving in with her and will be enrolling in another
school district.
Currently Susanna is not doing very well in school. She misses school and she tells the
helper it is because she is tired and that she does not have good food to eat. She has not told
the helper that she is looking for a place to live. Right now she is failing two of her classes
and she has one B and two Ds. Her boyfriend has missed a lot of school, too.
James and Samantha
James is 10 years old and he has a sister, Samantha, who is 8. At the beginning of the
school year, both of the children were attending Boone Elementary School. Both children
live with their aunt and uncle; their parents are in prison. In the middle of the scho.
A review of the growth of the Israel Genealogy Research Association Database Collection for the last 12 months. Our collection is now passed the 3 million mark and still growing. See which archives have contributed the most. See the different types of records we have, and which years have had records added. You can also see what we have for the future.
How to Add Chatter in the odoo 17 ERP ModuleCeline George
In Odoo, the chatter is like a chat tool that helps you work together on records. You can leave notes and track things, making it easier to talk with your team and partners. Inside chatter, all communication history, activity, and changes will be displayed.
How to Build a Module in Odoo 17 Using the Scaffold MethodCeline George
Odoo provides an option for creating a module by using a single line command. By using this command the user can make a whole structure of a module. It is very easy for a beginner to make a module. There is no need to make each file manually. This slide will show how to create a module using the scaffold method.
বাংলাদেশের অর্থনৈতিক সমীক্ষা ২০২৪ [Bangladesh Economic Review 2024 Bangla.pdf] কম্পিউটার , ট্যাব ও স্মার্ট ফোন ভার্সন সহ সম্পূর্ণ বাংলা ই-বুক বা pdf বই " সুচিপত্র ...বুকমার্ক মেনু 🔖 ও হাইপার লিংক মেনু 📝👆 যুক্ত ..
আমাদের সবার জন্য খুব খুব গুরুত্বপূর্ণ একটি বই ..বিসিএস, ব্যাংক, ইউনিভার্সিটি ভর্তি ও যে কোন প্রতিযোগিতা মূলক পরীক্ষার জন্য এর খুব ইম্পরট্যান্ট একটি বিষয় ...তাছাড়া বাংলাদেশের সাম্প্রতিক যে কোন ডাটা বা তথ্য এই বইতে পাবেন ...
তাই একজন নাগরিক হিসাবে এই তথ্য গুলো আপনার জানা প্রয়োজন ...।
বিসিএস ও ব্যাংক এর লিখিত পরীক্ষা ...+এছাড়া মাধ্যমিক ও উচ্চমাধ্যমিকের স্টুডেন্টদের জন্য অনেক কাজে আসবে ...
Executive Directors Chat Leveraging AI for Diversity, Equity, and InclusionTechSoup
Let’s explore the intersection of technology and equity in the final session of our DEI series. Discover how AI tools, like ChatGPT, can be used to support and enhance your nonprofit's DEI initiatives. Participants will gain insights into practical AI applications and get tips for leveraging technology to advance their DEI goals.
Strategies for Effective Upskilling is a presentation by Chinwendu Peace in a Your Skill Boost Masterclass organisation by the Excellence Foundation for South Sudan on 08th and 09th June 2024 from 1 PM to 3 PM on each day.
it describes the bony anatomy including the femoral head , acetabulum, labrum . also discusses the capsule , ligaments . muscle that act on the hip joint and the range of motion are outlined. factors affecting hip joint stability and weight transmission through the joint are summarized.
This slide is special for master students (MIBS & MIFB) in UUM. Also useful for readers who are interested in the topic of contemporary Islamic banking.
This presentation includes basic of PCOS their pathology and treatment and also Ayurveda correlation of PCOS and Ayurvedic line of treatment mentioned in classics.
1 TO Plaintiff Weltee Wolo, Pro Se, 3140 Northdale Bl
1. 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,
2. 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.,
3. Defendant.
Case No. ___________________
DEFENDANT’S ANSWERS TO
PLAINTIFF’S INTERROGATORIES TO
DEFENDANT (FIRST SET)
2
discovery in resolving the issues, and whether the burden or
expense of the proposed discovery
outweighs its likely benefit.
4. Defendant objects to the Interrogatories to the extent they
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.
4. 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.
7. Defendant objects to the Interrogatories to the extent they
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
5. 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-
3
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
6. 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
7. 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.
4
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
8. preparation of the Answers to these Interrogatories. Jaclyn
Vados also previously furnished
information used in the preparation of the Answers to these
Interrogatories.
INTERROGATORY NO. 2:
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.
ANSWER TO INTERROGATORY NO. 2:
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
9. 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
5
Plaintiff’s Complaint and the litigation in this matter.
Defendant reserves the right to supplement
10. this response as discovery is ongoing.
INTERROGATORY NO. 3:
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.
ANSWER TO INTERROGATORY NO. 3:
In addition to the General Objections, Defendant objects that
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-
11. 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.
INTERROGATORY NO. 4:
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
12. including holidays vacation pay, pension plans, and
insurance/benefit programs.
6
ANSWER TO INTERROGATORY NO. 4:
In addition to the General Objections, Defendant objects that
this Interrogatory is
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
13. 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.
INTERROGATORY NO. 5:
14. 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.
7
ANSWER TO INTERROGATORY NO. 5:
In addition to the General Objections, Defendant objects that
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
15. terminate Plaintiff’s employment in December 2020.
INTERROGATORY NO. 6:
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.
ANSWER TO INTERROGATORY NO. 6:
In addition to the General Objections, Defendant objects that
this Interrogatory is vague
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
16. her last stint of employment, Plaintiff would therefore have
reported to RN Dawn Hirsch and
Director of Nursing Jacklyn Vados.
8
INTERROGATORY NO. 7:
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.
ANSWER TO INTERROGATORY NO. 7:
In addition to the General Objections, Defendant objects that
this Interrogatory is
overboard and unduly burdensome, as Defendant has nearly 100
employees and dozens, if not
17. hundreds, of additional former employees during the time
period sought by this Interrogatory.
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.”). Subject to and
without waiving the foregoing Specific and General Objections,
Defendant answers as follows:
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
18. 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.
INTERROGATORY NO. 8:
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,
9
whether they have worked remotely over the past 2 years, name
of direct supervisor, and the
reason the employee separated from Defendant, if applicable.
ANSWER TO INTERROGATORY NO. 8:
In addition to the General Objections, Defendant objects that
this Interrogatory is
overboard and unduly burdensome. Defendant further objects
19. 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.”).
INTERROGATORY NO. 9:
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.
20. ANSWER TO INTERROGATORY NO. 9:
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,
Defendant answers as follows:
Defendant is available, through its counsel, to meet and confer
with Plaintiff regarding
this interrogatory.
10
INTERROGATORY NO. 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
21. 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.
ANSWER TO INTERROGATORY NO. 10:
In addition to the General Objections, Defendant objects that
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.
22. P. 33.03 that may contain relevant facts or information.
Defendant reserve the right to
supplement this response as discovery is ongoing.
INTERROGATORY NO. 11:
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.
ANSWER TO INTERROGATORY NO. 11:
In addition to the General Objections, Defendant objects that
this Interrogatory as it seeks
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
23. 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.
INTERROGATORY NO. 12:
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
ANSWER TO INTERROGATORY NO. 12:
24. In addition to the General Objections, Defendant objects that
this Interrogatory is
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 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 answers as follows:
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.
12
25. INTERROGATORY NO. 13:
Identify all statements that you allege or believe constitute,
contain, describe, or reflect an
admission against the interest of Plaintiff.
ANSWER TO INTERROGATORY NO. 13:
In addition to the General Objections, Defendant objects that
this Interrogatory as it seeks
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
without waiving the foregoing Specific and General Objections,
Defendant answers as follows:
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.
INTERROGATORY NO. 14:
26. Identify each instance in which Plaintiff received a performance
review during her
employment.
ANSWER TO INTERROGATORY NO. 14:
In addition to the General Objections, Defendant objects that
this Interrogatory is vague
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
without waiving the foregoing Specific and General Objections,
Defendant answers as follows:
Defendant refers Plaintiff to the 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.
27. 13
INTERROGATORY NO. 15:
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.
ANSWER TO INTERROGATORY NO. 15:
In addition to the General Objections, Defendant 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
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
without waiving the foregoing Specific and General Objections,
Defendant as follows:
28. Defendant refers Plaintiff to the documents produced by
Defendant pursuant to Minn. R.
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.
INTERROGATORY NO. 16:
Identify and describe in detail each instance in which Plaintiff
complained of
discrimination to Defendant.
ANSWER TO INTERROGATORY NO. 16:
In addition to the General Objections, Defendant objects that
this Interrogatory seeks
information that is already within Plaintiff’s possession,
custody, or control, and is already
within the knowledge of Plaintiff. Subject to and without
waiving the foregoing Specific and
General Objections, Defendant answers that the documents
produced by Defendant pursuant to
Minn. R. Civ. P. 33.03 contain relevant facts and information.
29. 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
INTERROGATORY NO. 17:
Identify all employees who were employed in the same position
as Plaintiff.
ANSWER TO INTERROGATORY NO. 17:
In addition to the General Objections, Defendant objects that
this Interrogatory is
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.
30. 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.”).
INTERROGATORY NO. 18:
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;
31. ANSWER TO INTERROGATORY NO. 18:
In addition to the General Objections, Defendant objects that
this Interrogatory is
overboard and unduly burdensome due to being indefinite as to
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
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
32. parties’ claims, are open to disclosure and, then, subject to an
appropriate Confidentiality Order
as the circumstances require.”).
INTERROGATORY NO. 19:
State whether you paid Plaintiff her earned but unpaid PTO at
the time of her termination.
ANSWER TO INTERROGATORY NO. 19:
In addition to the General Objections, Defendant objects that
this Interrogatory to the
extent it seeks a legal conclusion. Subject to and without
waiving the foregoing Specific and
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
33. 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.
INTERROGATORY NO. 20:
Describe in detail your investigation into the allegations raised
against Plaintiff,
including:
a. The name of each employee interviewed;
34. 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.
ANSWER TO INTERROGATORY NO. 20:
In addition to the General Objections, Defendant objects that
this Interrogatory is
overboard and unduly burdensome. Subject to and without
waiving the foregoing Specific and
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
35. responsive documents produced
pursuant to Minn. R. Civ. P. 33.03.
INTERROGATORY NO. 21:
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;
17
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.
ANSWER TO INTERROGATORY NO. 21:
In addition to the General Objections, Defendant objects that
this Interrogatory is
overboard and unduly burdensome due to being indefinite as to
36. time period and scope.
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. Subject to and without
waiving the foregoing Specific and General Objections,
Defendant answers as follows:
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 from a reasonable time period.
INTERROGATORY NO. 22:
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.
ANSWER TO INTERROGATORY NO. 22:
37. In addition to the General Objections, Defendant objects that
this Interrogatory is
overboard and unduly burdensome due to being indefinite as to
time period and scope.
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. Subject to and without
waiving the foregoing Specific and General Objections,
Defendant answers as follows:
18
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 from a reasonable time period.
AS TO OBJECTIONS:
Dated: November 29, 2021 SPENCER FANE LLP
By: /s/ Randi J. Winter
38. 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:
39. Its:
1
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
40. 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.
41. 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,
42. 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-
43. 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
44. 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
45. 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
46. 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
47. 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
48. 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.
REQUEST NO. 3: All Documents and Communications relating
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.
REQUEST NO. 4: All Documents and Communications relating
to, referring to,
supporting, and/or refuting the allegation that Defendant’s
stated reason for terminating You is a
49. mere pretext for discrimination and reprisal and/or has no
factual basis, as set forth in paragraphs
14–15 of the Complaint.
REQUEST NO. 5: All Documents and Communications relating
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.
REQUEST NO. 6: All Documents and Communications relating
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.
REQUEST NO. 7: All Documents and Communications relating
to, referring to,
supporting, and/or refuting the allegation that Defendant took
adverse actions against You in
50. reprisal to activity protected under MHRA, as set forth in
paragraphs 25–30 of the Complaint.
REQUEST NO. 8: All Documents and Communications relating
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.
REQUEST NO. 9: All Documents and Communications relating
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
51. relating to or referring to any of the allegations in the
Complaint and/or Your employment with
Defendant.
REQUEST NO. 12: All Documents and Communications
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,
52. 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.
REQUEST NO. 15: All Documents and Communications
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.
REQUEST NO. 16: All Documents and Communications
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.
53. REQUEST NO. 17: All Documents and Communications
relating to any complaint of
harassment, discrimination, or retaliation that you alleged
against any employer within the last ten
years.
REQUEST NO. 18: All Documents and Communications
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.
REQUEST NO. 19: All Documents and Communications
relating to the termination of
Your employment from any Employer, whether voluntary or
54. involuntary, occurring at any time
after the end of Your employment with Whispering Pines
Assisted Living, Inc.
REQUEST NO. 20: All Documents and Communications
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.
REQUEST NO. 23: All Documents and Communications
relating to, referring to,
55. 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.
REQUEST NO. 24: All Documents and Communications
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,
56. 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.
REQUEST NO. 26: All Documents and Communications
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
57. 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
58. 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.