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Judicial Watch • MarylandRussia

MarylandRussia

MarylandRussia

Page 1: MarylandRussia

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Number of Pages:8

Date Created:September 10, 2018

Date Uploaded to the Library:October 16, 2018

Tags:MarylandRussia, identify, Procedure, registered, matter, rules, Voters, MONTGOMERY, maryland, Scott, Civil, Attorney, September, COUNTY, federal, request, robert


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THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT MARYLAND
JUDICIAL WATCH, INC.,
Plaintiff
LINDA LAMONE, al.,
Defendants.
Case No. 17-cv-2006-EH
DEFENDANT LINDA LAMONE FIRST SET INTERROGATORIES PLAINTIFF JUDICIAL WATCH, INC.
Pursuant Rule the Federal Rules Civil Procedure, Defendant Linda
Lamone, State Administrator Elections, propounds this First Set Interrogatories
plaintiff, Judicial Watch, Inc. Judicial Watch and requests that Judicial Watch respond these interrogatories under oath within thirty (30) days accordance with the Federal
Rules Civil Procedure and the Instructions and Definitions set forth below.
DEFINITIONS
Notwithstanding any definitions set forth below, each word term used these
interrogatories intended have the broadest meaning permitted under the Federal Rules Civil Procedure. used these interrogatories, the following terms are
interpreted accordance with these definitions:
All means any and all any means any and all.
And and each encompasses both and and or. Both terms should construed disjunctively and conjunctively necessary bring within the scope the
interrogatory all documents that might otherwise construed falling outside its scope.
Communication means the transmittal any information any manner.
The term communication includes, but not limited to, any oral, written, electronic
correspondence and evidence thereof, matter how that correspondence evidence
stored, memorialized, fixed. furthermore includes, but not limited to, any
summaries, reviews, reports, notes, logs, records, journals, minutes, outlines concerning memorializing the transmittal information.
Document used its broadest sense and meant include all items
referred and included within the scope the Federal Rules Civil Procedure. The
term document specifically meant include, but not limited to, any and all
electronic documents and data, matter how they are stored. The term document also meant include, but not limited to, all original and non-identical copies, and all nonidentical drafts versions any document. identify document means state the document type
classification, general subject matter, date, author, addresses, and recipients; or,
alternatively, produce the document. the document has been destroyed, identify
also means state the date its destruction, the reason for its destruction, and the identity the person who destroyed it. identify person means provide that person full name, last known
address and telephone number, and last known job title and employer business
affiliation. Once person has been identified response request according this
definition, only the name the person needs listed response subsequent
discovery requesting the identification that person. identify incident event means, minimum, state the date
dates which the event occurred, identify the persons participating the event, state the
place places which the event occurred, and state with particularity what transpired
during the incident event.
Including means including, but not limited to.
Relating means concerning, constituting, evidencing, describing,
effecting, relating to, referring to, pertaining to, about, either directly indirectly,
being any way logically factually connected with the specified subject matter. Any
request for documents relating any subject matter includes request for documents
reflecting communication about that subject matter.
10.
You and your include the person whom these interrogatories are
addressed, and all that person agents, representatives, and attorneys.
INSTRUCTIONS
Respond with all information your possession, custody, control,
the possession, custody, control your agents, servants, employees, attorneys,
accountants, other persons acting purporting act your behalf. the extent provided the Federal Rules Civil Procedure, the
interrogatories are intended continuing nature. You are requested supplement
your responses the interrogatories new additional information responsive the
requests becomes available. used herein, the plural any word includes the singular, and the singular
includes the plural. used herein, the masculine gender any word includes the feminine and
the neuter, and the feminine any word includes the masculine and the neuter.
The past tense any verb used herein includes the present tense, and the
present tense includes the past tense. part any interrogatory should left unanswered merely because
objection interposed another part the interrogatory. partial incomplete
response provided, state that the answer partial incomplete, specify which portions the interrogatory have not been answered, and state with particularity the reason
reasons those portions have not been answered. asserting objection all part interrogatory based privilege,
work product, other protection from disclosure, identify the nature the privilege
protection.
Include the information set forth Federal Rule Civil Procedure
26(b)(5)(A)(ii) and Discovery Guideline 10(d). you perceive any ambiguity the instructions, definitions,
interrogatories contained herein, set forth the particular matter matters deemed
ambiguous and the construction applied answering. you object answering any interrogatory the grounds that responding
would unduly burdensome, describe the burden expense the proposed discovery.
INTERROGATORIES
Identify all persons likely have discoverable information that you may use support your claims rebut the defenses this case, and provide description the
subject matter all such information likely possessed each person.
Describe category and location all documents, electronically stored
information and tangible things that you have your possession, custody control and
may use support your claims rebut the defenses this case.
Describe category and location all documents, electronically stored
information and tangible things that you have your possession, custody control
relating Judicial Watch request for copy the list registered voters
Montgomery County, Maryland that the subject matter this lawsuit, including all
documents relating Judicial Watch decision request the voter list, the reasons
Judicial Watch made the request, the purposes for which Judicial Watch intends use the
list, and any broader effort obtain copies similar lists from other jurisdictions which
Judicial Watch request for copy the list registered voters Montgomery County,
Maryland, part.
Identify all persons who participated Judicial Watch decision request copy the list registered voters Montgomery County, Maryland that the subject
matter this lawsuit, and describe the role each person played the decision.
Identify all persons you consulted any way concerning Judicial Watch
request for copy the list registered voters Montgomery County, Maryland that
the subject matter this lawsuit, including any actual potential financial supporters
Judicial Watch.
Identify any communications you had with any third party, other than your
attorneys, concerning Judicial Watch request for copy the list registered voters
Montgomery County, Maryland that the subject this lawsuit, including your answer
the parties each communication, the subject matter each communication and the date each communication.
Identify any communications you had with any third party, other than your
attorneys, concerning this lawsuit, including your answer the parties each
communication, the subject matter each communication and the date each
communication.
Identify any other jurisdiction for which Judicial Watch has sought copy list registered voters, part broader effort obtain copies such lists which
Judicial Watch request for copy the list registered voters Montgomery County,
Maryland, part, including your answer identification those jurisdictions, any,
for which Judicial Watch has obtained copy any such list response its request. you contend that any defendant has made any admission and/or declaration
against interest relating any claims defenses involved this lawsuit, identify the
person making each such admission declaration, the substance each such admission declaration, the date each such admission declaration and identify all documents
relating each such admission declaration.
10.
Identify anyone you expect call witness this action, and for each
individual state with specificity the subject matter their testimony.
11.
Identify all documents that you provided actual potential financial
supporters Judicial Watch relating this lawsuit Judicial Watch request for
copy the list registered voters Montgomery County, Maryland.
12.
Identify any Russian nationals agents the Russian government with
whom you have communicated concerning this lawsuit, Judicial Watch request for copy the list registered voters Montgomery County, Maryland, the purposes for which
you are seeking copy the list registered voters Montgomery County, Maryland,
and/or any broader effort obtain copies similar lists from other jurisdictions which
Judicial Watch request for copy the list registered voters Montgomery County,
Maryland, part.
BRIAN FROSH
Attorney General Maryland
_/s/ Robert Scott________________
ROBERT SCOTT (Fed. Bar 24613)
Assistant Attorney General
Office the Attorney General
Civil Division
200 St. Paul Place
Baltimore, Maryland 21202
rscott@oag.state.md.us
(410) 576-7055; (410) 576-6955 (fax)
Dated: September 10, 2018
Attorneys for Defendants
CERTIFICATE SERVICE HEREBY CERTIFY that, this 10th day September, 2018, copy the
foregoing Interrogatories Plaintiff, was sent first class mail, postage pre-paid, and email to:
Robert Popper (rpopper@judicialwatch.org)
Judicial Watch, Inc.
425 Third Street SW, Suite 800
Washington, D.C. 20024
_/s/ Robert Scott____________________
Robert Scott