Discovery a. Interrogatories i. Work Product 1. Identify? 2.

Persons who made or assisted in the determination of the status of the material as work product. 3. ttorney!s" or other individual!s"who created?

#. Persons who had access to said work product $. Persons or agencies to which the alleged work product was provided %. &ow transferred? '. (he date and court proceeding wherein Defendant raised the )work product) privilege or otherwise o*+ected to the disclosure of the alleged work product., if any. -. (he date and ii. Pu*lic .ecords 1. Please identify *y make, model, serial num*er, and purchase date of the computer allegedly wiped of pu*lic records. 2. Please descri*e with specificity what actions and efforts were undertaken !if any" to determine whether Plaintiff had deleted Pu*lic .ecords. a. If any such actions and efforts were undertaken, please identify the individual!s" who participated in such actions and the dates of their participation. 3. Please descri*e with specificity what actions and efforts were undertaken !if any" to determine whether the pu*lic records alleged to have *een deleted were maintained, stored, or preserved in any other location. a. If any etc. #. If you are alleging that Plaintiff violated pu*lic records law in any manner other than, or in addition to, the deletion of pu*lic records, please specify the actions of Plaintiff constituting the alleged violation. $. /opies of all pu*lic records alleged to have *een deleted.

a. 0or each individual pu*lic record alleged to have *een deleted specify whether and where copies of such pu*lic record were maintained or kept in any other storage media, facility, server, computer, or )cloud). %. /opies of all documents showing or identifying the creator and custodian of each and every pu*lic record alleged to have *een deleted '. /opies of all documents and communications relating to any effort or investigation to determine or identify or retrieve the pu*lic records alleged to have *een deleted. -. /opies of all policies relating to the repair of non1functioning or misfunctioning computers. 2. /opy of +o* description for the I( director !or other designated +o* title of Plaintiff immediately prior to his discharge" *. .e3uest to Produce 2. 4ruid*os report 3. nswer to /ounterclaims, .eply, Incorporated 5otion to Dismiss !0ailure to 6tate a /ause of ction, failure to attach copies and e7hi*its", affirmative defenses !fraud on the court, illegality"

#. 5otion to 6trike $. $'.18$ %. 1.1'8 additional parties may *e *rought in relative to counterclaims !see also 1.1-8" '. 5otion for 5ore Definite 6tatement?