Fred Northrup filed a lawsuit against Acme Insurance Inc. and Helen Redmond alleging sexual harassment and discrimination. Northrup submitted requests for admissions, interrogatories, and production of documents from the defendants relating to Northrup's employment, complaints against Redmond, investigations into harassment claims, and criteria used in promotions. The requests covered topics such as Northrup's job performance reviews, complaints against Redmond, the hiring and disciplinary history of involved employees, and the company's anti-harassment policies and programs. The defendants were instructed to respond to the requests within 30 days.

1. IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
FRED NORTHRUP, §
Plaintiff, §
§
VS. § CIVIL ACTION NO. H-11-222
§
§
HELEN REDMOND, §
ACME INSURANCE INC., §
Defendant. §
PLAINTIFF’S FIRST SET OF REQUESTS FOR ADMISSIONS,
INTERROGATORIES, AND PRODUCTION OF DOCUMENTS
Fred Northrup., by his counsel, submits the following Requests for Admissions,
Interrogatories, and produce for inspection and copying the following documents within
the time and in the manner specified by these rules to Defendant Acme Insurnace, Inc.
and Defendant Helen Redmond, pursuant to FRCivP Rule 33, 34, and 36. The documents
shall be produced at the office of Jane Simpson within 30 days of receipt of the request at
10 a.m.
INSTRUCTIONS
If Acme Insurnace, Inc. (hereafter Defendant Acme) and Helen Redmond (hereafter
Defendant Redmond) fails to respond or object to any request within 30 days of the
service of the Requests, the matter shall be deemed admitted under Rule 36.
As is more fully set out in Rule 36(a), the Defendant must admit or deny each request,
and, where necessary, specify the parts of each request to which it objects or cannot in
good faith admit or deny. If the Defendant objects to only part of a Request, it must admit
or deny the remainder of the Request. In the event that the Defendant objects to or denies

2. any Request or portion of a Request, the Defendant must state the reasons for its
objection or denial.
These Requests shall be deemed continuing and supplemental answers shall be required if
you directly or indirectly obtain further information after your initial response as
provided by FRCivP Rule 26(e).
Each Request solicits all information obtainable by Defendant Acme, Inc and Defendant
Redmond. from Defendant’s attorneys, investigators, agents, employees and
representatives. If you answer a Request on the basis that you lack sufficient information
to respond, describe any and all efforts you made to inform yourself of the facts and
circumstances necessary to answer or respond.
DEFINITIONS
1. The word "or" is used herein in its inclusive sense unless the context clearly
requires otherwise.
2. Any reference to a specifically named person, corporation or other entity and any
reference generally to "person" shall include the employees, agents, representatives and
other persons acting on behalf thereof or through whom the referenced person acts. The
term "person" means and includes natural persons, corporations, partnerships, joint
ventures, sole proprietorships, associations, trusts, estates, firms and any other entity.
3. As used herein, "Plaintiff" means, unless otherwise indicated, Fred Northrup.
4. As used herein, "Defendant", shall be deemed to include Acme Insurance, Inc.
and Helen Redmond, as well as their agents, attorneys, representatives or any other
person acting on their behalf or on behalf of any one of them.

3. 5. The term “documents” has the meaning ascribed to it in Fed. R. Civ. P. 34(a) and
shall also include all originals, drafts, revisions and other non-identical copies (together
with all attachments thereto) of all such documents.
6. The relevant time period encompassed by these interrogatories is June 1,
2016 through the present, unless otherwise indicated expressly or by the context of the
question or request.
8. The term “identify” means (i) to provide the name, address, telephone number,
employer and job title of each individual; (ii) to provide the name, principal business
address, nature of juridical entity and state of organization of each entity; (iii) to provide
the date, author, recipient and subject matter of each document; and (iv) to provide with
respect to any oral communication, the time and place of making, the substance of the
communication and the identity of the makers, recipients and witnesses to the
communication.
9. The term “explain the basis” means to state all facts, identify all documents and
oral communications and describe all legal theories with respect to the subject matter of
the request.
10. The term “Company” means defendant Acme Insurance, Inc.
11. If the Company claims any privilege of non-production for any document or oral
communication containing information sought by this discovery, please identify each
such document or communication and explain the basis on which it is being withheld
from discovery.

4. FIRST SET OF ADMISSIONS
First Set of Admissions, Request 1. Admit that Plaintiff has been an employee for 10
years.
First Set of Admissions, Request 2. Admit that Plaintiff did not receive a promotion for
assistant risk control manager.
First Set of Admissions, Request 3. Admit that Plaintiff did receive the promotion.
First Set of Admissions, Request 4. Admit that Joe Bob David (“David”) has not been
employed as long as Plaintiff at your company.
First Set of Admissions, Request 5. Admit that Plaintiff has received favorable job
reviews with your company.
First Set of Admissions, Request 6. Admit that Plaintiff did not receive a favorable job
review for fiscal year 2016-2017.
First Set of Admissions, Request 7. Admit that Plaintiff’s credentials and qualifications
for assistant risk control manager were superior to David’s qualifications for assistant risk
control manager.
First Set of Admissions, Request 8. Admit that Defendant Redmond is Plaintiff’s
supervisor.
First Set of Admissions, Request 9. Admit that Plaintiff has made complaints against
Defendant Redmond for sexual harassment.
First Set of Admissions, Request 10. Admit that other employees in the same division
as Plaintiff have made complaints against Defendant Redmond for sexual harassment.
First Set of Admissions, Request 11. Admit that other employees who have had work-
related contact with Defendant Redmond have made complaints against Defendant
Redmond for sexual harassment.
First Set of Admissions, Request 12. Admit that no investigation was made of
Plaintiff’s sexual harassment charges against Defendant Redmond.
First Set of Admissions, Request 13. Admit that no discipline was taken against
Defendant Redmond for the allegations of sexual harassment.
First Set of Admissions, Request 14. Admit that discipline was taken against Plaintiff
for making charges of sexual harassment against Defendant Redmond.

5. PLAINTIFF’S FIRST SET OF INTERROGATORIES
1. With respect to Helen Redmond.
a) identify her direct supervisor
b) Describe her employment history with the Company and state her present
job title and the nature of her responsibilities; and
c) If she has ever been suspended, demoted, disciplined, or terminated
involuntarily by the Company (or any of its affiliates), specify the dates and
reasons for such actions.
2. Identify the individuals who were in charge of the office in Houston, Texas
[“office #1”] at all times during plaintiff’s employment there (including those individuals
who were in charge of the office during the absence of Mr. Northrup).
3. Identify plaintiff’s direct supervisors during the course of his employment with
the Company (and its affiliates) and identify each evaluation, written or oral, made by
such supervisors concerning plaintiff’s performance as an employee.
4. State whether the Plaintiff has received any reprimands, warnings or other written
or oral notice concerning his work performance prior June 30th, and identify all persons
who initiated and communicated them.
5. State whether any of the Company’s management officials or any outside
consultant made any inquiry or investigation into any allegations of sexual harassment at
office #1 during the period from January 1, 2016 through the present, and identify all
persons who made or assisted in such inquiry or investigation and identify all documents
referring or relating to such inquiry or investigation.

6. 6. Identify all questions directed to the Company’s affirmative action officer
concerning sexual harassment in accordance with the Company’s policy on harassment as
reported in the Acme Insurance, Inc. Employee Manual from time to time.
7. State each objective criterion relied upon by the Company in assessing plaintiff’s
work performance during the last three years of his employment.
8. Identify each male employee who worked under the supervision of the individual
named in interrogatory 1 who complained, charged, sued, or otherwise brought to the
attention of the Company any allegation of harassment, intimidation, or improper conduct
by the female supervisor or employee; and describe each allegation.
9. Identify each female employee who worked under the supervision of the
individual named in interrogatory 1 who complained, charged, sued, or otherwise brought
to the attention of the Company any allegation of harassment, intimidation, or improper
conduct by the female supervisor or employee; and describe each allegation.
10. State whether the Company received any communication when contemplating
hiring the individual named in interrogatory I that consisted of any allegation of
harassment, intimidation, or improper conduct by the female supervisor or employee; and
describe each allegation.
11. State whether the Company has been named or identified as a respondent or
defendant in any charge, complaint, investigation or other judicial or administrative
action in which it is alleged that employees of the Company in Houston, Texas sexually
harassed male or female employees.

7. 12. With respect to each charge, complaint, investigation or action identified in
answer 14, describe the nature and disposition of each such matter and identify the
persons named in the allegations.
13. Describe with particularity all programs, plans and policies of the Company
which are designed to prevent or minimize the risk of sexual harassment at the
Company’s [name of city], North Carolina Offices, and identify all persons who have
formulated, implemented and evaluated such programs, plans and policies.
14. Identify all persons you expect to call to testify at trial.
REQUEST FOR PRODUCTION OF DOCUMENTS
1. The personnel files of the following individuals: Fred Northrup, Helen Redmond,
and Joe Bob David.
2. All policies and programs concerning sexual harassment from before January 1,
2000.
3. All policies and programs concerning sexual harassment from between January 1,
2006 and July 5, 2016.
4. All policies and programs concerning sexual harassment after July 5, 2016
through to present.
5. All communications to employees about the programs and policies mentioned in
Requests 2-4.

8. 6. All correspondence, memoranda, and other documents addressed to or received
from personnel consultants (other than Company’s attorneys), which refer or relate to
sexual harassment.
7. All disclosures to federal, state, or local agencies and to the Company’s
accountants and underwriters since January 1, 2006 referring to or relating to sexual
harassment generally or any claims made by male employees alleging sexual harassment
in connection with their employment.
8. All disclosures to federal, state, or local agencies and to the Company’s
accountants and underwriters since January 1, 2006 referring to or relating to sexual
harassment generally or any claims made by female employees alleging sexual
harassment in connection with their employment.
9. All correspondence and other documents addressed to or received from the Texas
Workforce Commission, the Texas Industrial Commission, the Social Security
Administration, the Texas Department of Labor, the Equal Employment Opportunity
Commission or any other federal, state or local agency relating to the Company’s
employment of Fred Northrup or to the claims made by Fred Northrup against the
Company.
10. All documents referred to or encompassed by Company’s answers to
interrogatories 1-14.

9. 11. All other documents referring or relating to the subject matter of this action which
have been furnished to or reviewed by the Company’s attorneys in relation to their
defense of this action, except for those documents protected by a recognized privilege of
non-production.
12. A list of all documents which are being withheld from production by virtue of any
privilege of non-production or for any other reason. (This list should identify each
document by its name, date, author and recipient and specify the reason for withholding it
from production.)
This 26 day of December, 2016.
Respectfully submitted,
Simpson and Associates
______________________________
Jane Simpson
State Bar No. 01111111
Federal I.D. No. 9870
12 Memorial Drive, Suite 100
Houston, TX 77024
Telephone: (713)461-2839
Facsimile: (713)661-6930
js@jsandassociates.com
OF COUNSEL:

10. Simpson and Associates
12 Memorial Drive, Suite 100
Houston, TX 77024
Telephone: (713)461-2839
Facsimile: (713)661-6930
CERTIFICATE OF SERVICE
This is to certify that on this the ____ day of January, 2012, a copy of the foregoing
Notice of Hearing was served via CM/ECF filing:
Ken Barr
3300 West Alabama, Suite 500
Houston, Texas 77098
______________________________________
James Taylor