Erin Goecke

UNITED STATES DISTRICT COURT OF THE SOUTHERN DISTRICT OF

NEW YORK

Alice Bennett : Case No.: C18-2305

Plaintiff, :
Judge Herman
:

v. : PLAINTIFF’S FIRST SET OF

INTERROGATORIES
Rikards-Hayley :

Defendant. :

INTRODUCTION

Pursuant to Rules 46 and 47 of the United States District Court of the Southern
District of New York Rules of Civil Procedure, you are to answer the interrogatories
hereinafter set forth, separately, fully, in writing, and under oath. You should deliver a
true copy of your answer to the undersigned attorney within 30 days after the date of
service of these interrogatories.

DEFINITIONS
1. To “identify” a document or state the “identity of” a document shall mean to state
with respect thereto:
a. The identity of the person who prepared it;
b. The identity of the person who signed it or over whose signature it was or is
issued;
c. The identity of each person to whom it was addressed or distributed nature
and substance of the document with sufficient particularity to enable it to be
identified;
d. The date, if any, which the document bears; and
e. The present location of the document, including the identity of its custodian
or custodians; or in lieu thereof, attach a copy of said document to your
response to these interrogatories.
2. To “identify” or to state the “identity of” a person shall mean with respect thereto:
a. The person’s full name;
b. The person’s title and business or professional affiliation, if any, as of the
time to which the answer relates;
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c. The person’s present title and business or profession and residence

addresses.

INSTRUCTIONS

A. You are required by Rules 46 and 47 of the United States District Court of the
Southern District of New York Rules of Civil Procedure to:
1. Answer fully and factually each of the interrogatories hereinafter set out;
2. Furnish all information called for by said interrogatory;
3. Sign your response;
4. Swear to your response;
5. Serve same upon the undersigned attorney within thirty (30) days after
the date of service of these interrogatories. You are further instructed:
B. Every interrogatory herein shall be deemed a continuing interrogatory, and you
are to supplement your answers promptly if and when you obtain relevant
information in addition to, or in any way inconsistent with, your initial answer to
any interrogatory.
C. If you object to, or otherwise decline to answer, any portion of an interrogatory,
provide all information called for in that portion of the interrogatory to which you
do not object or which you do not decline to answer. If you object to an
interrogatory on the grounds that to provide an answer would constitute as an
undue burned, provide such requested information as can be supplied without
undertaking an undue burned. For these portions of any interrogatory to which
you object or otherwise decline to answer, state the reason for such objection or
declination.
D. The applicable period of time, unless otherwise provided shall be from February
20, 2018 to the date of answering these interrogatories.
E. If any answer is refused in whole or in part, on the basis of a claim of privilege or
exemption, state the following:
1. The nature of the privilege or exemption claimed;
2. The general nature of the matter withheld
3. Name(s) of person(s) to whom the information has been imparted; and
4. The extent, if any, to which the information will be provided subject to the
privilege or exemption

NOTE
IF ANY INTERROGATORY OR REQUEST IS OBJECTIONABLE, PLEASE CALL
COUNSEL FOR THE COMPLAINTANT BEFORE OBJECTING, IN ORDER TO
ATTEMPT TO NARROW THE QUESTION OR AVOID THE OBJECTIONABLE
PORTION OR ASPECT.

COMPLAINTANT’S INTERROGATORIES
1. What are the processes and procedures for hiring decisions at Rikards-Hayley?
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2. Who makes the hiring decisions?

3. What qualifications were being sought out for the manager position?

4. Is there an anti-harassment policy as Rikards-Hayley? Please state the policy, if

applicable.

5. Why did Mr. Blackwood’s Memo not make Ms. Bennett your first candidate for
the manager position?

6. Is there a policy against women are not allowed to delegate tasks to men?

7. Why is acceptable for men at Rikards-Hayley to be uncomfortable taking

directions from women?

8. What is the importance of Ms. Bennett’s physical appearance as being considered

a potential candidate for the manager position?

9. Was Ms. Bennett respected as a manager by the employees in her department?

10. How did the employees, working in Ms. Bennett’s department, like Ms. Bennett
as the acting manager?

11. Were any employees in the department allowed to give input on the hiring
decision when it came to Ms. Bennett? Explain why or why not.

12. Did Ms. Bennett make improvements in the department during the time she was
an acting manager? Explain how, if applicable.

13. What is the procedure/standard when deciding how much of a severance pay an
employee receives?
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14. How is Ms. Yardly more experienced and a better fit for the manager position?

15. Who made this ultimate decision?

16. Who witnessed the hostile work environment after Ms. Yardly was hired as the
manager? Please state specific persons.

17. What proof does Rikards-Hayley possess that Ms. Bennett was the person
causing a hostile environment, and not Ms. Yardly?

18. Who keeps employee personnel files and records?

19. Where are these records kept?

Respectfully Submitted,

Anthony Righetti, Esq.

Righetti, Morgan and Blake
34 Court Ave.
Greenville, New York
(555) 222-2222
arighetti@rmb.com

CERTIFICATE OF SERVICE

I hereby certify that a true and accurate copy of this document was served by
ordinary mail to Vanessa Groves, Esq, Attorney for Defendant, at 1 Main St., New York,
New York on this 9th day of February 2018.