Byron L. Mills,Esq.Nevada Bar No.
9955Mills, Mills& Anderson703 S. 8thStreetLas Vegas,Nevada 89101Telephone: (702) 386-0030Attorneys for Plaintiff . DISTRICT COURT CLARK COUNTY, NEVADA Clyde Wilson ) ) CaseNo. A-18-345239 )Plaintiff, ) Dept.No. 23 )vs. ) ) )Charles Jacobs )Dice & Jacobs Law Firm ) ) ) ) Defendants. )___________________________________ PLAINITFF’SFIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTSTO: CHARLES JACOBS, Defendant; Plaintiff, Clyde Wilson,by his undersigned attorneys, requests that Defendant, Charles Jacobs,answer the following interrogatories under oath pursuant to NRCP 33, withinthirty (30) days.
PRELIMINARY STATEMENTThe following preliminarystatement and definitions apply to each of the Interrogatories set forthhereinafter and are deemed to be incorporated therein:1. These Interrogatories call for all information (includinginformation contained in writings) that is known or available to you or yourattorney or others acting on your behalf or under your direction. 2.
Whenever you are asked to identify a person in answer to anyInterrogatory, state: (a) Their name;(b) Their last known address;3. Whereveryou are asked to identify a writing, please state a full description, includingbut not limited to:(a) The date;(b) The name of the person who prepared it;(c) The name of each person to whom it wasaddressed;(d) Its subject matter and its substance.4. Wheneveryou are unable to state an answer to these Interrogatories based upon yourpersonal knowledge, please state so, and instead identify the people of whichyou believe to have this knowledge.DEFINITIONS1. The term “you” or “your” meansthe Defendant, and all other persons acting or purporting to act on Defendant’sbehalf.
2. The term “document” means each original andcopy, regardless of origin and location of any written or recordedmaterial, including computer stored and computer retrievable information.3. The term “and”means and/or and the term “or” means and/or. INTEROGATORYNO.
1: Explain the Defendant’s exact reasoningin the termination of the Plaintiff’s employment in full detail including any incompetencyor inadequate work performance. REQUEST FORPRODUCTION NO. 1: Provide all current and previous employee filesfrom the year of 2000 up to current date, including but not limited to:a.) Resumesb.) Evaluationsc.) Complaints and warnings INTERROGATORYNO.
2: Identify all people/employees/colleagueswho have knowledge of facts or statements concerning the allegations given. REQUEST FORPRODUCTION NO. 2: Produce alldocuments concerning all known people’s knowledge of facts relevant to theallegations made in the previously entered Complaint. INTERROGATORYNO. 3: Please listany and all people who the Defendant will call as a witness at trial and providea brief summary of their testimony. REQUEST FOR PRODUCTION NO. 3: Provide any documents concerning the witness/witnesseslisted by Defendant in the above response to Plaintiff’s Interrogatory No.
3. INTERROGATORYNO. 4: Identify all people/employees/colleagueswith who the Defendant has communicated with concerning the allegations madeand describe in detail. REQUEST FORPRODUCTION NO.
4: Produce anydocuments concerning the communications described in Plaintiff’s InterrogatoryNo. 2. INTERROGATORYNO.
5: Identify all people who have fileda complaint against or concerning the Defendant’s conduct in the workplace. Anycomplaints regarding employment discrimination or a hostile work environment,describe in detail and any accompanying actions or reprimands made by the Defendant. REQUEST FOR PRODUCTION NO. 5: Produce all documents concerning any and all complaintsidentified regarding employment discrimination or a hostile work environment fromthe Defendant.