Central District of California

1 ABDUL WAHED R.
IBRAHIM
1847 W. 74TH ST.
2 LOS ANGELES CA 90047
559-395-5030
3 Ibrahimraefeal@gmail.com
Plaintiff In Pro Per
4
8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA
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) Case No.: 2: 18-cv-04514-DMG-SK
11 ABDUL WAHED R. IBRAHHIM, )
) PLAINTIFF ABDUL WAHED R.
12 Plaintiff, ) IBRAHIM RESPONSES TO
) DEFENDANT MORGAN SOUTHERN,
13 vs. ) INC. INTERROGATORIES,
MOGAN SOUTHERN, INC., ) SET ONE
14 )
MORGAN SOUTHERN ) Judge: Hon. Dolly Gee
15 TRUCKING A DELAWARE )
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CORPORATION; AND DOES 1
50, INCLUSIVE,
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Defendant(s)
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PROPOUNDING PARTY: DEFENDANT MORGAN
21 SOUTHERN, INC.
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RESPONDING PARTY: ABDUL WAHED R. IBRAHIM
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SET: ONE
25 Plaintiff, Abdul Wahed R. Ibrahim (“Plaintiff”) hereby responds to Morgan

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Southern Trucking, Inc. (“Defendant”) First Set of interrogatories as follows:
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PLAINTIFF’S RESPONSE TO DEFENDANT INTERROGATORIES, SET ONE

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GENERAL OBJECTIONS
2 Plaintiff object to Defendant’s first set of interrogatories on the following

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grounds, and incorporates these general objections in each response without restating
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them:
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6 1. Attorney-Client Privilege. Plaintiff objects to each interrogatory to the

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extent that it seeks to discover information that is protected by the attorney-client
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9 privilege, including confidential communications between or among Plaintiff and its

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attorneys.
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2. Work Product Privilege. Plaintiff objects to each interrogatory to the
13 extent that it seeks to discover information that falls within the work product privilege,
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including the mental impressions, conclusions, opinions or legal theories of an attorney or
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16 other representative of Plaintiff concerning this litigation.

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3. Trial Preparation Materials. Plaintiff objects to each Interrogatory to the extent
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19 that it seeks to discover information that was acquired or developed in anticipation of

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litigation, including those materials protected from discovery pursuant to Cal. Code Civ.
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Procedure §§ 2018.010, et. seq.
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23 4. Information not Presently Known by Plaintiff. Plaintiff objects to each

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interrogatory to the extent that it seeks to impose an obligation upon Plaintiff to gather
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26 information not presently known to it or included in documents

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currently in its possession, custody or control. Discovery in this case continues,
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2

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and Plaintiff reserves the right to modify or amend its answers.
2 5. Other Objections. In providing this response to Defendant’s discovery request,

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Plaintiff does not waive or intend to waive:
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5 a. Objections as to competency, relevancy, materiality or admissibility;

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b. Rights to object on any grounds to the use of any responses herein in any
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8 subsequent proceedings, including the trial of this or any other actions;

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c. Objections as to vagueness and ambiguity; and
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d. Rights to object further to this or any other further discovery request in this
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12 proceeding.
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Discovery is in its initial stages; therefore, Plaintiff reserves the right to supplement
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15 any or all o its responses as additional information is located, identified or learned

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through ongoing discovery.
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PLAINTIFF’S RESPONSE TO DEFENDANT’S INTERROGATORIES
19 INTERROGATORY NO 1:
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Identify all weeks in which you contend you were not paid at least minimum wage
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22 for all hours worked.

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RESPONSE TO NO 1:
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INTERROGATORY NO 2:
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3

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For each week identify in your response to Interrogatory 1, identify the total
2 number hours you worked.

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RESPONSE TO NO 2:
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5 INTERROGATORY NO 3:
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For each week identified in your response to Interrogatory number 1, identify the
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8 amount you were underpaid.

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RESPONSE TO NO 3
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INTERROGATORY NO 4:
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15 Identify all weeks in which you contend you worked overtime hours.
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RESPONSE TO NO 4:
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19 INTERRAGATORY NO 5:
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For each week identified in your response to Interrogatory number 4, identify the
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22 amount of overtime pay you contend that you are owed.

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RESPONSE TO NO 5:
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INTERRAGATORY NO 6:
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4

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Or each week identified in your response to Interrogatory number 4, identify the
2 amount of overtime pay you contend that you are owed.

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RESPONSE TO REQUEST NO 6:
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INTERRAGATORY NO 7:
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8 Describe all facts supporting your contention that Defendant willfully failed to pay
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you promptly upon discharge or resignation all compensation owed, as required by Cal.
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Lab. Code §§ 201-203.
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12 RESPONSE TO NO 7:
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INTERRAGATORY NO 8:
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15 If you ever communicated any concern regarding overtime pay to anyone

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employed by Defendant, Identify the content of your communications and the person(s)
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to whom you expressed your concern.
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State the dollar amount of compensatory damages you seek.
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5

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INTERRAGATORY NO 10:
2 State how You calculated the damage amount provided in your answer to
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Interrogatory No. 6.
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RESPONSE TO NO 10:
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Describe all facts supporting Your claim for attorney fees, interest, and costs.
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15 INTERAGATORY NO 12:
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Identify and describe, for each individual or entity you were employed by or
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provided services to, during the last 10 years to the present, and your relationship with
19 that individual or entity. Such description shall include, but not be limited to, the name
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and address of the individual or entity, the dates of the employment or services, the name
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22 of your immediate supervisor or contact person, the job titles you held, description of the
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services provided or job duties, whether such position was full-time or part-time, the
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25 reason you left such employment or stopped providing such Services, and a history of
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your salary or rate of compensation.
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RESPONSE NO 12:
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6

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2 Identify the date, source, and amount of all income and compensation received by
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you or attributable to you from January 1, 2014 to April 26, 2019.
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RESPONSE TO NO 13:
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INERRAGATORY NO 14:
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Identify each and every Person to whom you have disclosed your occupation,
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12 independent contractor status, or employment status since January 1, 2014, including, but
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not limited to, disclosures on loan or credit applications, purchase orders, membership
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15 applications, and all other disclosures.

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RESPONSE NO 14:
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Identify each and every person with whom you have discussed in an way the
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22 allegations in, or that relate to, your claims against Defendant.

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RESPONSE NO 15:
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7

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State the name, web address, and user name for all blogs, online forums, and social
2 networking websites that you have belonged or had membership to from January 1, 2014
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to April 26, 2019.
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8 INTERRAGATORY NO. 17:

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Identify the user name and email address for any Facebook account used by you
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from January 2014 to April 26, 2019.
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15 Identify the user name, registration information, account detail, login information,
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and any other identifying information for any job board or job search information, and
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any other identifying information for any job board or job search websites for which you
19 are (or were) a member, including but not limited to: Hot Jobs, Career Builder,
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Monster, job.com and salesjobhunter.com from January 1, 2014 to April 26, 2019.
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22 RESPONSE TO NO 18
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8

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Dated: June 7, 2019
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By: _____________________
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8 Abdul Wahed R. Ibrahim

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1 ABDUL WAHED R.

8 UNITED STATES DISTRICT COURT

25 Plaintiff, Abdul Wahed R. Ibrahim (“Plaintiff”) hereby responds to Morgan

PLAINTIFF’S RESPONSE TO DEFENDANT INTERROGATORIES, SET ONE

2 Plaintiff object to Defendant’s first set of interrogatories on the following

6 1. Attorney-Client Privilege. Plaintiff objects to each interrogatory to the

9 privilege, including confidential communications between or among Plaintiff and its

16 other representative of Plaintiff concerning this litigation.

19 that it seeks to discover information that was acquired or developed in anticipation of

23 4. Information not Presently Known by Plaintiff. Plaintiff objects to each

26 information not presently known to it or included in documents

PLAINTIFF’S RESPONSE TO DEFENDANT INTERROGATORIES, SET ONE

2 5. Other Objections. In providing this response to Defendant’s discovery request,

5 a. Objections as to competency, relevancy, materiality or admissibility;

8 subsequent proceedings, including the trial of this or any other actions;

15 any or all o its responses as additional information is located, identified or learned

22 for all hours worked.

PLAINTIFF’S RESPONSE TO DEFENDANT INTERROGATORIES, SET ONE

2 number hours you worked.

8 amount you were underpaid.

22 amount of overtime pay you contend that you are owed.

PLAINTIFF’S RESPONSE TO DEFENDANT INTERROGATORIES, SET ONE

2 amount of overtime pay you contend that you are owed.

15 If you ever communicated any concern regarding overtime pay to anyone

PLAINTIFF’S RESPONSE TO DEFENDANT INTERROGATORIES, SET ONE

PLAINTIFF’S RESPONSE TO DEFENDANT INTERROGATORIES, SET ONE

15 applications, and all other disclosures.

22 allegations in, or that relate to, your claims against Defendant.

PLAINTIFF’S RESPONSE TO DEFENDANT INTERROGATORIES, SET ONE

8 INTERRAGATORY NO. 17:

PLAINTIFF’S RESPONSE TO DEFENDANT INTERROGATORIES, SET ONE

8 Abdul Wahed R. Ibrahim

PLAINTIFF’S RESPONSE TO DEFENDANT INTERROGATORIES, SET ONE

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