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Filing # 140256256 E-Filed 12/13/2021 01:57:11 PM
IN THE CIRCUIT COURT OF THE
SECOND JUDICIAL CIRCUIT, IN AND
FOR GADSDEN COUNTY, FLORIDA
CATHERINE ROBINSON,
Plaintiff,
v. CASE NO.: 2020-CA-000859
CITY OF QUINCY,
Defendant.
DEFENDANT CITY OF QUINCY’S AMENDED RESPONSE TO.
PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
Pursuant to Florida Rule of Civil Procedure 1.350, Defendant, CITY OF QUINCY,
responds to Plaintiff's request for production as follows:
|. Exhibits
The following documents are produced throughout this Response. The responses
below will identify which exhibit is responsive to each Request.
aed pre Lee) EFTTA)
4. Personnel Files
A | Personnel File of Catherine 1-83, 275-418
Robinson, redacted
B_ | Personnel File of Ted Beason, 692-732
redacted
C_ | Personnel File of David 876-968
Rittman, redacted
D_ | Personnel File of Gloria 810-851, 1854-1858
Woodard, redacted
E | Personnel File of Vancheria 1002-1061
Perkins, redacted
F | Personnel File of Diane 1808-1853
Matheney, redacted
G | Personnel File of Donna 969-1001
Reeves, redacted
H_ | Personnel File of Amanda 852-875Matthews, redacted
| Personnel File of Linda Ortega, 734-781
redacted
J Personnel File of Glenn Sapp 545-691
redacted
K_ | Personnel File of Ann 1905-1945
Sherman, redacted
L_ | Personnel File of Jack McLean, 1883-1904
Jr., redacted
2. Email chain between Jack McLean, 1804-1807
Jr. and Maria Francis and
attachment, dated July 5-6, 2017,
redacted portion according to
attorney-client privilege.
3. City Budgets
A FY 2014 2015 Budget 1062-1322
B 2015-2016 Budget 1323-1387
c 2017 Budget 1388-1449
D 2018 Budget 1450-1507
E 2019 Budget 1508-1570
F 2020 Overall Budget 1571-1628
G 2020-2021 Adopted Budget 1629-1719
H 2021 Adopted Budget 1720-1803
4. Organization Chart from 2019 1882
5. City Personnel Handbook 419-544
6. Job Descriptions
A Customer Service Director 1859-1861
B Human Resources Director 1862-1863
Cc Building and Planning 1864-1866
Director
D Finance Director 1867-1871
E Fire Chief 1872-1873
F Parks and Recreation 1874-1876
Director
G Police Chief 1877-1878
H Utilities Director 1879-1881
7. Plaintiff's statements
A Plaintiff's Answers to EEOC 96
Questions
B Attachment to Catherine 97-98
Robinson's Grievance
Cc Amended Charge of 99-102
Discrimination
D EEOC Complaint 106
E Plaintiff's Timeline of Events 222
8. Plaintiff's Tax Returns, redacted 236-2479. Declaration of Jack McLean, Jr. 1980-1981
10. FMLA Documents
A Sylvia Hicks FMALA request, 1946-1957
redacted
B Diane Matheny FMLA 1958-1971
request, redacted
Cc E’Mond Miller FMLA request, 1972-1979
redacted
D Glenn Sapp FMLA request, 1982-1985
redacted
E Tonayne Bryant FMLA 1986-1989
request, redacted
F DeCody Fagg FMLA request, 1999-2002
redacted
G Justin Garrison FMLA 2003-2006
request, redacted
H Shawanna Moye FMLA 2007-2010
request, redacted
| Jane Parsons FMLA request, 2011-2015
redacted
J Betty Powell FMLA request, 2016-2021
redacted
K Jarvis Taylor FMLA request, 2022-2025
redacted
L Helen Whitehead FMLA 2026-2029
request, redacted
M Toren Wood FMLA request, 1990-1993
redacted
41. E-mail from Vancheria Perkins to 1994-1996
Jack McLean dated June 4, 2019,
with attached letter.
Il. Responses
1. The entire personnel, disciplinary, investigative, time and attendance, IA,
supervisor, and payroll files for the following: Plaintiff, Maria Francis, Ted Beason, David
Rittman, Ann Sherman, Gloria Woodard, Vancheria Perkin, Diane Methaney, Donna Reave,
Amanda Matthews, Linda Ortega, Jack McLean and Glenn Sapp in Defendant’s possession
and/orcontrol.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. The time, attendance, and payroll files for these individuals
are not relevant to Plaintiffs claims or the City’s defenses in this matter. Subject to and
without waiving these objections, see Exhibit 1. The City is not in possession of the
personnel file for Maria Francis.2. All emails that reference Plaintiff for the time period covered by this request.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All e-mails related to Plaintiff in any way for the six-year time
span in this request are not relevant to Plaintiff's claims or the City’s defenses in this
matter. Additionally, this information is not stored in a reasonably accessible, centralized
location. The burden or expense to the City to locate and produce this discovery outweighs
its likely benefit, considering the needs of the case and the importance of these documents
in resolving the issues in this matter. Additionally, the e-mail accounts of former employees
are not reasonably accessible to the City due to undue burden. The City also objects to this
request because it seeks documents protected by the attorney-client privilege. Subject to
and without waiving these objections, the City has searched for all e-mails related to
Plaintiffs termination, alleged disability, sick leave, medical conditions, customer
complaints, negative comments about her supervisors, and requests for accommodation in
the possession of Ronte Harris, Angela Grant Sapp, Keith Dowdell, Vancheria Starling
(Perkins), Ann Sherman, and Jack McLean, Jr., other than those e-mails protected by a
recognized privilege. See Exhibits 2 and 11.
3. All evaluations that Plaintiff received during the entire course of her
employment with Defendant.
RESPONSE: See Exhibit 1-A.
4. All documents upon which Defendant relied in the preparation of the
performance evaluations referenced in request 3 above.
RESPONSE: None in the possession of the City other than those contained in Exhibit 1-A.
5. All documents upon which Defendant relied in the decision to terminate
Plaintiff.
RESPONSE: None in the City’s possession.
6. Any and/or all documents and recordings reflecting communication,
including without limitation emails, voicemails, text and/or phone calls between Jack
McLean, Chief Glenn Sapp, Mayor Angela Grant-app, Commissioner Keith Dowdell and
Commissioner Ronte Harris involved in the decision to terminate Plaintiff.
RESPONSE: The City objects to this request because the e-mail account of former
employees Glenn Sapp is not reasonably accessible due to undue burden or cost. Subject to
and without waiving this objection, see Exhibit 2.
7. All FMLA requests, notices and/or papers (redacting confidential medical
information) submitted by all employees of Defendant during the time period covered by
this request.RESPONSE: The City objects to this request because It is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All FMLA requests, notices and/or papers (redacting
confidential medical information) submitted by all employees of Defendant during the 6-
year time period covered by this request are not relevant to Plaintiff's claims or the City’s
defenses in this matter. Additionally, the City objects to this request because information
listing every employee who has submitted FMLA requests during this time period is not
reasonably accessible because it is not stored in a centralized location, so production of
these documents would present an undue burden to the City. Subject to and without
waiving this objection, the City produces the FMLA requests from 2018 to the present to
the present to the best of its knowledge, see Exhibit 10.
8. All documents in which employees of Defendant requested sick leave of more
than5 days (redacting confidential medical information) during the time period covered by
this request.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents in which employees of Defendant requested
sick leave of more than 5 days are not relevant to Plaintiff's claims or the City’s defenses in
this matter. Subject to and without waiving this objection, see Exhibit 10.
9. The personnel, disciplinary and payroll records for all persons for whom
files/records are produced in response to requests 7 and 8 above.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. The personnel, disciplinary and payroll records for all
persons for whom files/records are produced in response to requests 7 and 8 above are not
relevant to Plaintiff's claims or the City’s defenses in this matter.
10. The position descriptions for all persons for whom documents are produced
in response to requests 7 and 8 above for the time period covered by this request.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. The position descriptions for all persons for whom
documents are produced in response to requests 7 and 8 above are not relevant to
Plaintiff's claims or the City’s defenses in this matter. Additionally, the job titles for each
employee are listed in their FMLA requests.
11. All documents that constitute all reports of investigations and all documents
collected and/or created during any and/or all investigations of any matter pertaining to
Plaintiff and any and/or all complaints she made against, to and/or about Jack McLean,
Ted Beason, MariaFrancis and/or any other persons, during the entire course of her
employment with Defendant.
RESPONSE: None in the City’s possession.12. All documents that constitute all reports of investigations and all documents
collected and/or created during any and/or all investigations of any matter pertaining any
and/or all complaints that were made against Plaintiff.
RESPONSE: None in the City’s possession.
13. All files and documents pertaining to any and/or all complaints made against
Plaintiff by employees and/or customers/citizens for the time period covered herein.
RESPONSE: None in the City’s possession.
14. — Alldocuments showing each and every disciplinary action taken against any
and/orall current and/or former employees of Defendant while Jack McLean was the City
Manager for the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. The disciplinary documents for every employee under the
supervision of City Manager McLean are not relevant to Plaintiffs claims or the City’s
defenses in this matter. Additionally, this information is not reasonably accessible because
it is not stored in a centralized location, so production of these documents would present
an undue burden to the City. The burden or expense to the City to locate and produce this
discovery outweighs its likely benefit, considering the needs of the case and the
importance of these documents in resolving the issues in this matter.
15. — Alldocuments showing each and every disciplinary action taken against any
and/orall current and/or former employees of Defendant while Mayor Angela Grant-Sapp
was in the mayor position for the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. The disciplinary documents for every employee while Angela
Grant Sapp was mayor are not relevant to Plaintiff's claims or the City’s defenses in this
matter. Additionally, this information is not reasonably accessible because it is not stored in
a centralized location, so production of these documents would present an undue burden to
the City. The burden or expense to the City to locate and produce this discovery outweighs
its likely benefit, considering the needs of the case and the importance of these documents
in resolving the issues in this matter.
16. All documents showing each and every disciplinary action taken against any
and/orall current and former employees of Defendant while Commissioner Keith Dowdell
was acommissioner for the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. The disciplinary documents for every employee while Keith
Dowdell has been a commissioner are not relevant to Plaintiff's claims or the City’s defensesin this matter. Additionally, this information is not reasonably accessible because it is not
stored in a centralized location, so production of these documents would present an undue
burden to the City. The burden or expense to the City to locate and produce this discovery
outweighs its likely benefit, considering the needs of the case and the importance of these
documents in resolving the issues in this matter.
17. — Alldocuments showing each and every disciplinary action taken against any
and/orall current and former employees of Defendant while Commissioner Ronte Harris
was a commissioner for the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. The disciplinary documents for every employee while Ronte
Harris has been a commissioner are not relevant to Plaintiff's claims or the City’s defenses
in this matter. Additionally, this information is not reasonably accessible because it is not
stored in a centralized location, so production of these documents would present an undue
burden to the City. The burden or expense to the City to locate and produce this discovery
outweighs its likely benefit, considering the needs of the case and the importance of these
documents in resolving the issues in this matter.
18. All documents showing each and every disciplinary action taken against any
and/orall current and former employees of Defendant during the time that Ann Sherman
was in the HR position with Defendant for the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. The disciplinary documents for every employee while Ann
Sherman was in the HR position are not relevant to Plaintiff's claims or the City’s defenses
in this matter. It is undisputed that Ann Sherman was not a City employee at the time of
Plaintiff's termination. Additionally, this information is not reasonably accessible because it
is not stored in a centralized location, so production of these documents would present an
undue burden to the City. The burden or expense to the City to locate and produce this
discovery outweighs its likely benefit, considering the needs of the case and the importance
of these documents in resolving the issues in this matter.
19. All documents that discuss Plaintiff for the last year of her employment with
Defendant including without limitation all documents that discuss her time off work and/or
her termination.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents that discuss Plaintiff for the last year of her
employment with the City are not relevant to Plaintiff's claims or the City’s defenses in this
matter. Additionally, this information is not reasonably accessible because it is not stored in
a centralized location, so production of these documents would present an undue burden to
the City. The burden or expense to the City to locate and produce this discovery outweighsits likely benefit, considering the needs of the case and the importance of these documents
in resolving the issues in this matter. Additionally, see the City’s response to Request No. 2
above. As to the request for all documents that discuss her time off work and/or
termination, please see Exhibits 1-A and 2.
20. All emails authored and/or received by the following persons that reference
Plaintiff: Maria Francis, Ann Sherman, Ted Beason, Glenn Sapp, Gloria Woodard,
Vancheria Perkins, Dianne Methaney, Donna Reaves, Amanda Matthews, Linda Ortega,
Jack McLean, Mayor Grant-Sapp, Commissioner Keith Dowdell and Commissioner Ronte
Harris.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents that reference Plaintiff in any way that were
authored and/or received by the following persons Maria Francis, Ann Sherman, Ted
Beason, Glenn Sapp, Gloria Woodard, Vancheria Perkins, Dianne Methaney, Donna Reaves,
Amanda Matthews, Linda Ortega, Jack McLean, Mayor Grant-Sapp, Commissioner Keith
Dowdell and Commissioner Ronte Harris, are not relevant to Plaintiff's claims or the City’s
defenses in this matter. Additionally, the e-mail accounts of former employees Maria
Francis, Ted Beason, Glenn Sapp, Gloria Woodard, Diane Matheny, Donna Reaves, Amanda
Matthews, and Linda Ortega are not reasonably accessible due to undue burden or cost. The
City objects to this request because it seeks documents protected by the attorney-client
privilege. As for the non-privileged e-mails of employees Ann Sherman, Vancheria Perkins,
Jack McLean, Jr., Mayor Grant-Sapp, Commissioner Keith Dowdell and Commissioner Ronte
Harris, see the City’s response to Request No. 2 above.
21. All emails authored and/or received by the following persons referencing any
and/or all persons requesting FEMLA or sick leave including without limitation Plaintiff for
the time period covered by this request: Maria Francis, Ann Sherman, Ted Beason, Gloria
Woodard, Jack McLean, Angela Grant-Sapp, Keith Dowell and Ronte Harris.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. Plaintiff's claims are not related to FMLA leave in any way.
Additionally, the request for every e-mail from these individuals referencing any employee
who ever requested sick leave in a 6-year time frame is not reasonably calculated to lead to
the discovery of admissible evidence, but rather is calculated to lead to the production of
mostly irrelevant documents while placing an undue burden on the City to locate and
produce every routine sick leave request for every City employee in a 6-year span. This
information is not stored in a reasonably accessible, centralized location, so it would it be an
undue burden on the City to locate and produce these documents. The burden or expense to
the City to locate and produce this discovery outweighs its likely benefit, considering the
needs of the case and the importance of these documents in resolving the issues in this
matter. The City also objects to this request because it seeks documents protected by the
attorney-client privilege. As for documents related to Plaintiff's request for sick leave, see
Exhibit 1-A.22. All emails that reference the changes in the work environment and computer
area between Defendant's IT department and David Rittman and/or any other employees
of the Defendant during the time period covered here in.
RESPONSE: The City objects to this request because the e-mail accounts of former
employee David Rittman is not reasonably accessible due to undue burden or cost. As for
the e-mails of current employees, see the City’s response to Request No. 2 above.
23. All emails that reference and/or refer to Plaintiff's leave and/or termination
on or around July 9, 2018.
RESPONSE: The City objects to this request because it seeks documents protected by the
attorney-client privilege. Subject to and without waiving this objection, see the City’s
response to Request Nos. 2 and 6 above.
24. All emails sent and/or received by Ted Beason regarding Plaintiffs
performance evaluations.
RESPONSE: See the City’s response to Requests No. 20 above.
25. All emails sent and/or received by Jack McLean regarding Plaintiff's
performance evaluations.
RESPONSE: None in the City's possession.
26. All documents Defendant received from any and/or all healthcare providers
and/orphysicians about and/or regarding Plaintiff, whether they were received directly from
these providers or Plaintiff.
RESPONSE: See Exhibit 1-A.
27. All files including any and/or all reports of investigations and all documents
collected and/or created during any and/or all investigations of any matter pertaining to
Plaintiff.
RESPONSE: None in the City’s possession.
28. The personnel, payroll, and disciplinary files for all persons who have been
hired and/or transferred into the last position that Plaintiff held with Defendant after her
termination onJuly 9, 2018.
RESPONSE: None in the City’s possession.
29. The personnel, payroll and disciplinary files for all persons who have been
hired and/or transferred to replace Plaintiff in the last position she held with Defendant.RESPONSE: None in the City’s possession.
30. All notes taken by Maria Francis as a result of all conversations she had with
Plaintiff and/or any other person about Plaintiff.
Rl NSE: See Exhibit 1-A.
31. All notes taken by Ted Beason about Plaintiff's job duties
RESPONSE: None in the City’s possession.
32. All documents reflecting all communications between Ted Beason and Jack
McLean regarding Plaintiff.
RESPONSE: See the City’s response to requests No. 2 and 20 above.
33. All documents identifying all persons hired by Defendant under Jack
McLean’s direct and/or indirect supervision during the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents identifying every person the City has hired
while Jack McLean has been City Manager in the past 6 years are not relevant to Plaintiff's
claims or the City’s defenses in this case. Additionally, this information is not reasonably
accessible because it is not stored in a centralized location, so production of these
documents would present an undue burden to the City. The burden or expense to the City to
locate and produce this discovery outweighs its likely benefit, considering the needs of the
case and the importance of these documents in resolving the issues in this matter.
34. All documents identifying all persons terminated by Defendant under Jack
McLean’s direct and/or indirect supervision during the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents identifying every person the City has
terminated while Jack McLean has been City Manager are not relevant to Plaintiff's claims
or the City’s defenses in this case. Additionally, this information is not reasonably accessible
because it is not stored in a centralized location, so production of these documents would
present an undue burden to the City. The burden or expense to the City to locate and
produce this discovery outweighs its likely benefit, considering the needs of the case and
the importance of these documents in resolving the issues in this matter.
35. All documents identifying all positions that have been eliminated under the
direct and/or indirect supervision of Jack McLean, Ted Beason, Angela Gran-Sapp, Keith
Dowdell and Ronte Harris.RESPONSE: The City produces the City budgets for 2015-2021, which list the City’s
personnel positions every budget year, see Exhibit 3.
36. All proposed and enacted organizational charts for Defendant for the time
period covered by this request.
RESPONSE: See Exhibit 4.
37. All documents discussing position eliminations, downsizing and/or a
reduction in force during the time period covered by this request.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents discussing downsizing, a reduction in force, or
the elimination of any position in the 6-year span of this request are not relevant to
Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not
reasonably accessible because it is not stored in a centralized location, so production of
these documents would present an undue burden to the City. The burden or expense to the
City to locate and produce this discovery outweighs its likely benefit, considering the needs
of the case and the importance of these documents in resolving the issues in this matter.
Additionally, see the City’s responses to Request Nos. 2 and 20 above.
38. All documents and job descriptions showing all positions considered to be a
supervisor position under Jack McLean’s direct and/or indirect supervision during the time
periodcovered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents and job descriptions showing all positions
considered to be a supervisor position under Jack McLean's direct and/or indirect
supervision during the time period covered herein are not relevant to Plaintiff's claims or the
City’s defenses in this matter. Subject to and without waiving this objection, the City
provides the policies defining the Exempt Executive Employee positions that are exempt
from the Career Service employment appeal provisions of the Personnel Rules and
Regulations, which are City Personnel Policies, 1.03 and 1.04, and the job descriptions for
those positions. See Exhibits 5 and 6.
39. All meeting minutes, notes, audio recordings, and/or agendas of all staff
meetings held for the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All meeting minutes, notes, audio recordings, and/or
agendas of all staff meetings held for the 6-year time period under this request are not
relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this
information is not stored in a reasonably accessible, centralized location. The burden or
expense to the City to locate and produce this discovery outweighs its likely benefit,
considering the needs of the case and the importance of these documents in resolving theissues in this matter.
40. All minutes for all City Council/Commission meetings of Defendant for the
time period January 1, 2017 to date.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All minutes for all City Council/Commission meetings of
Defendant for the time period January 1, 2017 to date are not relevant to Plaintiff's claims
or the City’s defenses in this matter. Additionally, these documents are equally available to
Plaintiff on the City’s website, avaliable at: http://www.myaquincy.net/i/appointed-
officials/city-clerk/commission-agendas-2.
41. All documents including without limitation emails and proposed and
enacted organizational charts reflecting communications between Defendant, Jack McLean,
Ted Beason, Maria Francis, Ann Sherman and/or any and/or all other persons pertaining to
position eliminations, sick leave, evaluations, department reorganizations and employee
terminations for the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents reflecting all communications between
Defendant, Jack McLean, Ted Beason, Maria Francis, Ann Sherman and/or any and/or all
other persons pertaining to position eliminations, sick leave, evaluations, department
reorganizations and employee terminations for every City employee for the 6-year time span
covered herein, regardless of whether these documents are related to Plaintiff or her claims
in any way, are not relevant to Plaintiff's claims or the City’s defenses in this matter.
Additionally, this information is not stored in a reasonably accessible, centralized location.
The burden or expense to the City to locate and produce this discovery outweighs its likely
benefit, considering the needs of the case and the importance of these documents in
resolving the issues in this matter. Additionally, see the City’s responses to Request Nos. 2
and 20 above.
42. All emails between Defendant, Ted Beason, Maria Francis, Ann Sherman,
Vancheria Perkins and Jack McLean pertaining to Plaintiff's job duties and coverage while
she was on leave.
RESPONSE: See the City’s response to Request Nos. 2 and 20 above.
43. All meeting minutes, notes, audio recordings and/or documents produced
during all staff and City Commission/Council meetings held on or around August 2018.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All meeting minutes, notes, audio recordings and/or
documents produced during all staff and City Commission/Council meetings held on or
around August 2018 are not relevant to Plaintiffs claims or the City’s defenses in this
matter. Additionally, the agendas and minutes for these meetings are equally available toPlaintiff on the City’s website, avaliable at: http://www.myaquincy.net/i/appointed-
officials/city-clerk/commission-agendas-2.
44. All organizational charts for City of Quincy that were in place during Plaintiff's
employment and for the time period covered herein.
RESPONSE: As for organizational Charts for the City that were in place during Plaintiff's
employment, none in the City’s possession. As for any organizational charts that were in
place during the time period covered herein, see Exhibit 4.
45. All budgets for Defendant for each year covered by this request.
RESPONSE: See Exhibit 3.
46. All documents that Defendant relies on to support any and/or all claims that
Plaintiff's position was eliminated.
RESPONSE: None in the City’s possession.
47. All documents upon which Defendant relies to show that Defendant had a
budget shortfall that resulted in the elimination of Plaintiff's position and/or otherwise
adversely affectedPlaintiff’s position.
RESPONSE: None in the City’s possession.
48. All budget documents identifying all persons who lost their jobs and/or were
adversely affected by budget shortfalls.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. Additionally, Plaintiffs requested time span is overbroad
and seeks documents completely unrelated to Plaintiff's claims or the City’s defenses in
this matter. Additionally, this information is not reasonably accessible because it is not
stored in a centralized location, so production of these documents would present an undue
burden to the City. The burden or expense to the City to locate and produce this discovery
outweighs its likely benefit, considering the needs of the case and the importance of these
documents in resolving the issues in this matter.
49. All documents that identifying all persons whose positions were eliminated in
calendar years 2017, 2018, 2019 and 2020.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents that identifying all persons whose positions
were eliminated in calendar years 2017, 2018, 2019 and 2020 are not relevant to
Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not
reasonably accessible because it is not stored in a centralized location, so production ofthese documents would present an undue burden to the City. The burden or expense to the
City to locate and produce this discovery outweighs its likely benefit, considering the needs
of the case and the importance of these documents in resolving the issues in this matter.
Subject to and without waiving this objection, the City produces the City budgets for the
requested years, which lists the City’s positions for each year. See Exhibit 3.
50. All policies, procedures, rules and regulations that were applicable to
Plaintiff's employment with Defendant including without limitation such documents relating
to Defendant's hiring process, disciplinary process, termination, leave (paid, unpaid and
FMLA), predetermination hearings, disability accommodations (ADA), and Defendant’s
grievance process.
RESPONSE: See City Personnel Handbook, Exhibit 5.
51. All emails showing all communication between the following persons
regarding the ELWP: Plaintiff, Marvin Bailey, Yolanda Hernandez, Shelby Jefferson, David
Worthington, Kim Hodges, Nana Gatlin, and/or Linda Williams.
RESPONSE: The City is unaware of the identities of these individuals.
52. All documents identifying all accommodations that Defendant
provided to Plaintiff during the time period covered by this request.
RESPONSE: The City objects to this request because it Is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery to the extent it seeks documents related to any
accommodations, such as sick leave, the City provided to Plaintiff for various medical
conditions while she was employed with the City. To the extent that this request seeks
documents identifying all accommodations that Defendant provided to Plaintiff for the
alleged disability she claims in this case, see Exhibit 1-A.
53. All documents showing that it would have been an unreasonable
hardship on defendant to accommodate Plaintiff.
RESPONSE: Without Plaintiff identifying the accommodation Plaintiff requested, the City is
unable to respond to this request.
54. All documents identifying all accommodations provided to all current
and/or former employees of Defendant for the time period covered by this request.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents identifying all accommodations provided to all
current and/or former employees of Defendant for the time period covered by this request
are not relevant to Plaintiff's claims or the City’s defenses in this matter. Plaintiff's
requested time span is overbroad and seeks documents completely unrelated to Plaintiff's
claims or the City’s defenses in this matter. Additionally, this information is not reasonablyaccessible because it is not stored in a centralized location, so production of these
documents would present an undue burden to the City. The burden or expense to the City to
locate and produce this discovery outweighs its likely benefit, considering the needs of the
case and the importance of these documents in resolving the Issues in this matter.
55. All documents Defendant received related to Plaintiff disability and
accommodations for returning to work.
RESPONSE: See Exhibit 1-A for documents related to Plaintiff's claimed disability and
doctor’s note for returning to work. Otherwise, none in the City’s possession.
56. All documents that Francis, Beason, Sherman, McLean, Dowdell, created
about Plaintiff during the time period covered by this request.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents that Francis, Beason, Sherman, McLean,
Dowdell, created about Plaintiff in the 6-year time span covered by this request are not
relevant to Plaintiffs claims or the City’s defenses in this matter. Additionally, this
information is not reasonably accessible because it is not stored in a centralized location, so
production of these documents would present an undue burden to the City. The burden or
expense to the City to locate and produce this discovery outweighs its likely benefit,
considering the needs of the case and the importance of these documents in resolving the
issues in this matter. Additionally, this request seeks documents protected by the attorney
client and work product privileges. Additionally, see the City’s response to Request Nos. 2
and 20 above. Subject to and without waiving these objections, see Exhibits 1-A and 2.
57. All documents that contain any and/or all discussions of Plaintiff's requested
accommodations and/or time off work that she submitted on or around July 9, 2018.
RESPONSE: See the City’s response to Requests No. 2 and 20 above. Otherwise, none in
the City’s possession.
58. All documents that discuss and/or set forth the reason that on or around
July 9,2018, Plaintiff's job position was eliminated.
RESPONSE: None in the City’s possession.
59. All documents that discuss Plaintiff's evaluations during the time period
covered by this request.
RESPONSE: None in the City’s possession.
60. All emails that Plaintiff sent to Defendant and any supervisor and/or
coworker regarding the workload and stress level of the position she held for the time
covered by this requesthere in.RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All emails that Plaintiff sent to Defendant and any supervisor
and/or coworker regarding the workload and stress level of the position she held for the 6-
year period covered by this request are not relevant to Plaintiff's claims or the City’s
defenses in this matter. Plaintiff claims disability discrimination based on pain in her neck.
E-mails that are purely concerning her workload and stress level are not relevant to her
claims. Additionally, this information is not reasonably accessible because it is not stored in
a centralized location that is accessible to the City, so production of these documents would
present an undue burden to the City. The burden or expense to the City to locate and
produce this discovery outweighs its likely benefit, considering the needs of the case and
the importance of these documents in resolving the issues in this matter. Additionally, see
the City’s response to Request Nos. 2 and 20 above.
61. All emails that Plaintiff sent to Defendant regarding her leave, medical
condition and accommodations for returning to work.
RESPONSE: The City objects to this request because Plaintiff's former employee e-mail
account is not reasonably accessible to the City due to undue burden. Additionally, see the
City’s response to Request Nos. 2 and 20 above.
62. All evaluations prepared on or about Ted Beason, Ann Sherman and Maria
Francisduring the time period covered by this request for all employees under their
supervision.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All evaluations prepared on or about Ted Beason, Ann
Sherman and Maria Francis during the time period covered by this request for all
employees under their supervision are not relevant to Plaintiff's claims or the City’s
defenses in this matter. Additionally, this information is not reasonably accessible because
it is not stored in a centralized location that is accessible to the City, so production of these
documents would present an undue burden to the City. The burden or expense to the City
to locate and produce this discovery outweighs its likely benefit, considering the needs of
the case and the importance of these documents in resolving the issues in this matter.
Subject to and without waiving these objections, see Exhibits 1-B and 1-K.
63. All evaluations prepared on or about Plaintiff during the entire course of her
employment with Defendant.
RESPONSE: See Exhibit 1-A.
64. All documents that Defendant prepared and submitted to the Florida
Commission on Human Relations (FCHR) and/or EEOC in response to all charges of
discrimination and/or retaliation filed by Plaintiff.
RESPONSE: The City objects to this request to this request because It seeks informationprotected by the work-product privilege.
65. All documents that were authored by and/or at the direction of Jack McLean
aboutand/or regarding Plaintiff.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents that were authored by and/or at the direction
of Jack McLean about and/or regarding Plaintiff in the 6-year time span covered by this
request are not relevant to Plaintiff's claims or the City’s defenses in this matter.
Additionally, this information is not reasonably accessible because it is not stored in a
centralized location, so production of these documents would present an undue burden to
the City. The burden or expense to the City to locate and produce this discovery outweighs
its likely benefit, considering the needs of the case and the importance of these documents
in resolving the issues in this matter. Subject to and without waiving this objection, See
Exhibits 1-A, 2, and 3.
66. All documents showing all responses to Plaintiffs application and/or request
for sick leave in or around April 2018.
RESPONSE: See Exhibit 1-A.
67. Alldocuments created about and/or regarding Plaintiff including without
limitation documents about Plaintiff's request for workplace accommodations.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents created about and/or regarding Plaintiff in the
6-year time span covered by this request are not relevant to Plaintiff's claims or the City’s
defenses in this matter. Additionally, this information is not reasonably accessible because
it is not stored in a centralized location, so production of these documents would present an
undue burden to the City. The burden or expense to the City to locate and produce this
discovery outweighs its likely benefit, considering the needs of the case and the importance
of these documents in resolving the issues in this matter. See the City’s response to
Request Nos. 2, 20, and 22 above.
68. — All documents in which Defendant discussed Plaintiff's position elimination
on or around July 9, 2018.
RESPONSE: None in the City’s possession.
69. All documents created by and/or at the direction of Jack McLean about
and/or regarding Plaintiff.
RESPONSE: See the City’s response to request number 65 above.
70. All documents received or created by Defendant’s human resources officepersonnel that reference Plaintiff.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents received or created by Defendant’s human
resources office personnel that reference Plaintiff in the 6-year time span covered by this
request are not relevant to Plaintiff's claims or the City’s defenses in this matter.
Additionally, this information is not reasonably accessible because it is not stored in a
centralized location, so production of these documents would present an undue burden to
the City. The burden or expense to the City to locate and produce this discovery outweighs
its likely benefit, considering the needs of the case and the importance of these documents
in resolving the issues in this matter. Subject to and without waiving these objections, see
Exhibit 1-A.
71. All documents that reference and/or support Plaintiff's July 2018 termination.
RESPONSE: See Exhibit 1-A and 2.
72. All documents that were created by Ted Beason and/or Jack McLean and/or
any employee about allegations of customer complaints that implicate and/or discuss
Plaintiff.
RESPONSE: _ See the City’s response to Request No. 2 above. Otherwise, none in the City’s
possession.
73. Alldocuments that were provided to Defendant’s Human Resources about
Plaintiff.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents provided to the Human Resources
Department at any time for the 6-year period covered by this request are not relevant to
Plaintiff's claims or the City defenses in this matter. Subject to and without waiving this
objection. See Exhibit 1-A.
74. All documents showing all communications including without limitation
emails, between any and all of Defendant’s employees that reference Plaintiff.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents showing all communications including without
limitation emails, between any and all of Defendant's employees that reference Plaintiff in
any way for the 6-year time span covered by this request are not relevant to Plaintiffs claims
or the City’s defenses in this matter. Additionally, this information is not reasonably
accessible because it is not stored in a centralized location, so production of these
documents would present an undue burden to the City. The e-mail accounts of former
employee are not reasonably accessible to the City due to undue burden. The burden orexpense to the City to locate and produce this discovery outweighs its likely benefit,
considering the needs of the case and the importance of these documents in resolving the
issues in this matter. The City also objects to this request because it seeks documents
protected by the attorney-client privilege. See the City’s response to Request Nos. 2 and 20
above. Subject to and without waiving these objections, see Exhibit 2.
75. — All emails and documents authored by Plaintiff about her termination and
position elimination.
RESPONSE: See Exhibit 7 and the City’s response to Request No. 61 above.
76. ~All emails between Plaintiff and Defendant during the time period covered
herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All emails between Plaintiff and Defendant discussing any
topic for the 6-year time span covered by this request are not relevant to Plaintiff's claims or
the City’s defenses in this matter. See the City’s response to Request Nos. 2, 20, and 61
above.
77. All documents that identify all persons under the supervision of Jack McLean
during the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documents that identify all persons under the supervision
of Jack McLean during the 6-year time span covered by this request are not relevant to
Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not
stored in a reasonably accessible, centralized location. The burden or expense to the City to
locate and produce this discovery outweighs its likely benefit, considering the needs of the
case and the importance of these documents in resolving the issues in this matter.
78. All rules, regulations, policies and procedures regarding employee
evaluations and/or FMLA leave during the time period covered herein.
RESPONSE: See Exhibit 5.
79. All documentation showing any and/or all complaints filed against Jack
McLean during the time period covered herein.
RESPONSE: The City objects to this request because it is overbroad and not reasonably
calculated to lead to the discovery of admissible evidence. This request seeks documents
outside the scope of discovery. All documentation showing any and/or all complaints filed
against Jack McLean during the 6-year time span covered by this request are not relevant to
Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not
reasonably accessible because it is not stored in a centralized location, so production of
these documents would present
Preview
Filing # 140256256 E-Filed 12/13/2021 01:57:11 PM IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT, IN AND FOR GADSDEN COUNTY, FLORIDA CATHERINE ROBINSON, Plaintiff, v. CASE NO.: 2020-CA-000859 CITY OF QUINCY, Defendant. DEFENDANT CITY OF QUINCY’S AMENDED RESPONSE TO. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION Pursuant to Florida Rule of Civil Procedure 1.350, Defendant, CITY OF QUINCY, responds to Plaintiff's request for production as follows: |. Exhibits The following documents are produced throughout this Response. The responses below will identify which exhibit is responsive to each Request. aed pre Lee) EFTTA) 4. Personnel Files A | Personnel File of Catherine 1-83, 275-418 Robinson, redacted B_ | Personnel File of Ted Beason, 692-732 redacted C_ | Personnel File of David 876-968 Rittman, redacted D_ | Personnel File of Gloria 810-851, 1854-1858 Woodard, redacted E | Personnel File of Vancheria 1002-1061 Perkins, redacted F | Personnel File of Diane 1808-1853 Matheney, redacted G | Personnel File of Donna 969-1001 Reeves, redacted H_ | Personnel File of Amanda 852-875Matthews, redacted | Personnel File of Linda Ortega, 734-781 redacted J Personnel File of Glenn Sapp 545-691 redacted K_ | Personnel File of Ann 1905-1945 Sherman, redacted L_ | Personnel File of Jack McLean, 1883-1904 Jr., redacted 2. Email chain between Jack McLean, 1804-1807 Jr. and Maria Francis and attachment, dated July 5-6, 2017, redacted portion according to attorney-client privilege. 3. City Budgets A FY 2014 2015 Budget 1062-1322 B 2015-2016 Budget 1323-1387 c 2017 Budget 1388-1449 D 2018 Budget 1450-1507 E 2019 Budget 1508-1570 F 2020 Overall Budget 1571-1628 G 2020-2021 Adopted Budget 1629-1719 H 2021 Adopted Budget 1720-1803 4. Organization Chart from 2019 1882 5. City Personnel Handbook 419-544 6. Job Descriptions A Customer Service Director 1859-1861 B Human Resources Director 1862-1863 Cc Building and Planning 1864-1866 Director D Finance Director 1867-1871 E Fire Chief 1872-1873 F Parks and Recreation 1874-1876 Director G Police Chief 1877-1878 H Utilities Director 1879-1881 7. Plaintiff's statements A Plaintiff's Answers to EEOC 96 Questions B Attachment to Catherine 97-98 Robinson's Grievance Cc Amended Charge of 99-102 Discrimination D EEOC Complaint 106 E Plaintiff's Timeline of Events 222 8. Plaintiff's Tax Returns, redacted 236-2479. Declaration of Jack McLean, Jr. 1980-1981 10. FMLA Documents A Sylvia Hicks FMALA request, 1946-1957 redacted B Diane Matheny FMLA 1958-1971 request, redacted Cc E’Mond Miller FMLA request, 1972-1979 redacted D Glenn Sapp FMLA request, 1982-1985 redacted E Tonayne Bryant FMLA 1986-1989 request, redacted F DeCody Fagg FMLA request, 1999-2002 redacted G Justin Garrison FMLA 2003-2006 request, redacted H Shawanna Moye FMLA 2007-2010 request, redacted | Jane Parsons FMLA request, 2011-2015 redacted J Betty Powell FMLA request, 2016-2021 redacted K Jarvis Taylor FMLA request, 2022-2025 redacted L Helen Whitehead FMLA 2026-2029 request, redacted M Toren Wood FMLA request, 1990-1993 redacted 41. E-mail from Vancheria Perkins to 1994-1996 Jack McLean dated June 4, 2019, with attached letter. Il. Responses 1. The entire personnel, disciplinary, investigative, time and attendance, IA, supervisor, and payroll files for the following: Plaintiff, Maria Francis, Ted Beason, David Rittman, Ann Sherman, Gloria Woodard, Vancheria Perkin, Diane Methaney, Donna Reave, Amanda Matthews, Linda Ortega, Jack McLean and Glenn Sapp in Defendant’s possession and/orcontrol. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. The time, attendance, and payroll files for these individuals are not relevant to Plaintiffs claims or the City’s defenses in this matter. Subject to and without waiving these objections, see Exhibit 1. The City is not in possession of the personnel file for Maria Francis.2. All emails that reference Plaintiff for the time period covered by this request. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All e-mails related to Plaintiff in any way for the six-year time span in this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not stored in a reasonably accessible, centralized location. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. Additionally, the e-mail accounts of former employees are not reasonably accessible to the City due to undue burden. The City also objects to this request because it seeks documents protected by the attorney-client privilege. Subject to and without waiving these objections, the City has searched for all e-mails related to Plaintiffs termination, alleged disability, sick leave, medical conditions, customer complaints, negative comments about her supervisors, and requests for accommodation in the possession of Ronte Harris, Angela Grant Sapp, Keith Dowdell, Vancheria Starling (Perkins), Ann Sherman, and Jack McLean, Jr., other than those e-mails protected by a recognized privilege. See Exhibits 2 and 11. 3. All evaluations that Plaintiff received during the entire course of her employment with Defendant. RESPONSE: See Exhibit 1-A. 4. All documents upon which Defendant relied in the preparation of the performance evaluations referenced in request 3 above. RESPONSE: None in the possession of the City other than those contained in Exhibit 1-A. 5. All documents upon which Defendant relied in the decision to terminate Plaintiff. RESPONSE: None in the City’s possession. 6. Any and/or all documents and recordings reflecting communication, including without limitation emails, voicemails, text and/or phone calls between Jack McLean, Chief Glenn Sapp, Mayor Angela Grant-app, Commissioner Keith Dowdell and Commissioner Ronte Harris involved in the decision to terminate Plaintiff. RESPONSE: The City objects to this request because the e-mail account of former employees Glenn Sapp is not reasonably accessible due to undue burden or cost. Subject to and without waiving this objection, see Exhibit 2. 7. All FMLA requests, notices and/or papers (redacting confidential medical information) submitted by all employees of Defendant during the time period covered by this request.RESPONSE: The City objects to this request because It is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All FMLA requests, notices and/or papers (redacting confidential medical information) submitted by all employees of Defendant during the 6- year time period covered by this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, the City objects to this request because information listing every employee who has submitted FMLA requests during this time period is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. Subject to and without waiving this objection, the City produces the FMLA requests from 2018 to the present to the present to the best of its knowledge, see Exhibit 10. 8. All documents in which employees of Defendant requested sick leave of more than5 days (redacting confidential medical information) during the time period covered by this request. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents in which employees of Defendant requested sick leave of more than 5 days are not relevant to Plaintiff's claims or the City’s defenses in this matter. Subject to and without waiving this objection, see Exhibit 10. 9. The personnel, disciplinary and payroll records for all persons for whom files/records are produced in response to requests 7 and 8 above. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. The personnel, disciplinary and payroll records for all persons for whom files/records are produced in response to requests 7 and 8 above are not relevant to Plaintiff's claims or the City’s defenses in this matter. 10. The position descriptions for all persons for whom documents are produced in response to requests 7 and 8 above for the time period covered by this request. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. The position descriptions for all persons for whom documents are produced in response to requests 7 and 8 above are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, the job titles for each employee are listed in their FMLA requests. 11. All documents that constitute all reports of investigations and all documents collected and/or created during any and/or all investigations of any matter pertaining to Plaintiff and any and/or all complaints she made against, to and/or about Jack McLean, Ted Beason, MariaFrancis and/or any other persons, during the entire course of her employment with Defendant. RESPONSE: None in the City’s possession.12. All documents that constitute all reports of investigations and all documents collected and/or created during any and/or all investigations of any matter pertaining any and/or all complaints that were made against Plaintiff. RESPONSE: None in the City’s possession. 13. All files and documents pertaining to any and/or all complaints made against Plaintiff by employees and/or customers/citizens for the time period covered herein. RESPONSE: None in the City’s possession. 14. — Alldocuments showing each and every disciplinary action taken against any and/orall current and/or former employees of Defendant while Jack McLean was the City Manager for the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. The disciplinary documents for every employee under the supervision of City Manager McLean are not relevant to Plaintiffs claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. 15. — Alldocuments showing each and every disciplinary action taken against any and/orall current and/or former employees of Defendant while Mayor Angela Grant-Sapp was in the mayor position for the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. The disciplinary documents for every employee while Angela Grant Sapp was mayor are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. 16. All documents showing each and every disciplinary action taken against any and/orall current and former employees of Defendant while Commissioner Keith Dowdell was acommissioner for the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. The disciplinary documents for every employee while Keith Dowdell has been a commissioner are not relevant to Plaintiff's claims or the City’s defensesin this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. 17. — Alldocuments showing each and every disciplinary action taken against any and/orall current and former employees of Defendant while Commissioner Ronte Harris was a commissioner for the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. The disciplinary documents for every employee while Ronte Harris has been a commissioner are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. 18. All documents showing each and every disciplinary action taken against any and/orall current and former employees of Defendant during the time that Ann Sherman was in the HR position with Defendant for the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. The disciplinary documents for every employee while Ann Sherman was in the HR position are not relevant to Plaintiff's claims or the City’s defenses in this matter. It is undisputed that Ann Sherman was not a City employee at the time of Plaintiff's termination. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. 19. All documents that discuss Plaintiff for the last year of her employment with Defendant including without limitation all documents that discuss her time off work and/or her termination. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents that discuss Plaintiff for the last year of her employment with the City are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighsits likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. Additionally, see the City’s response to Request No. 2 above. As to the request for all documents that discuss her time off work and/or termination, please see Exhibits 1-A and 2. 20. All emails authored and/or received by the following persons that reference Plaintiff: Maria Francis, Ann Sherman, Ted Beason, Glenn Sapp, Gloria Woodard, Vancheria Perkins, Dianne Methaney, Donna Reaves, Amanda Matthews, Linda Ortega, Jack McLean, Mayor Grant-Sapp, Commissioner Keith Dowdell and Commissioner Ronte Harris. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents that reference Plaintiff in any way that were authored and/or received by the following persons Maria Francis, Ann Sherman, Ted Beason, Glenn Sapp, Gloria Woodard, Vancheria Perkins, Dianne Methaney, Donna Reaves, Amanda Matthews, Linda Ortega, Jack McLean, Mayor Grant-Sapp, Commissioner Keith Dowdell and Commissioner Ronte Harris, are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, the e-mail accounts of former employees Maria Francis, Ted Beason, Glenn Sapp, Gloria Woodard, Diane Matheny, Donna Reaves, Amanda Matthews, and Linda Ortega are not reasonably accessible due to undue burden or cost. The City objects to this request because it seeks documents protected by the attorney-client privilege. As for the non-privileged e-mails of employees Ann Sherman, Vancheria Perkins, Jack McLean, Jr., Mayor Grant-Sapp, Commissioner Keith Dowdell and Commissioner Ronte Harris, see the City’s response to Request No. 2 above. 21. All emails authored and/or received by the following persons referencing any and/or all persons requesting FEMLA or sick leave including without limitation Plaintiff for the time period covered by this request: Maria Francis, Ann Sherman, Ted Beason, Gloria Woodard, Jack McLean, Angela Grant-Sapp, Keith Dowell and Ronte Harris. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. Plaintiff's claims are not related to FMLA leave in any way. Additionally, the request for every e-mail from these individuals referencing any employee who ever requested sick leave in a 6-year time frame is not reasonably calculated to lead to the discovery of admissible evidence, but rather is calculated to lead to the production of mostly irrelevant documents while placing an undue burden on the City to locate and produce every routine sick leave request for every City employee in a 6-year span. This information is not stored in a reasonably accessible, centralized location, so it would it be an undue burden on the City to locate and produce these documents. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. The City also objects to this request because it seeks documents protected by the attorney-client privilege. As for documents related to Plaintiff's request for sick leave, see Exhibit 1-A.22. All emails that reference the changes in the work environment and computer area between Defendant's IT department and David Rittman and/or any other employees of the Defendant during the time period covered here in. RESPONSE: The City objects to this request because the e-mail accounts of former employee David Rittman is not reasonably accessible due to undue burden or cost. As for the e-mails of current employees, see the City’s response to Request No. 2 above. 23. All emails that reference and/or refer to Plaintiff's leave and/or termination on or around July 9, 2018. RESPONSE: The City objects to this request because it seeks documents protected by the attorney-client privilege. Subject to and without waiving this objection, see the City’s response to Request Nos. 2 and 6 above. 24. All emails sent and/or received by Ted Beason regarding Plaintiffs performance evaluations. RESPONSE: See the City’s response to Requests No. 20 above. 25. All emails sent and/or received by Jack McLean regarding Plaintiff's performance evaluations. RESPONSE: None in the City's possession. 26. All documents Defendant received from any and/or all healthcare providers and/orphysicians about and/or regarding Plaintiff, whether they were received directly from these providers or Plaintiff. RESPONSE: See Exhibit 1-A. 27. All files including any and/or all reports of investigations and all documents collected and/or created during any and/or all investigations of any matter pertaining to Plaintiff. RESPONSE: None in the City’s possession. 28. The personnel, payroll, and disciplinary files for all persons who have been hired and/or transferred into the last position that Plaintiff held with Defendant after her termination onJuly 9, 2018. RESPONSE: None in the City’s possession. 29. The personnel, payroll and disciplinary files for all persons who have been hired and/or transferred to replace Plaintiff in the last position she held with Defendant.RESPONSE: None in the City’s possession. 30. All notes taken by Maria Francis as a result of all conversations she had with Plaintiff and/or any other person about Plaintiff. Rl NSE: See Exhibit 1-A. 31. All notes taken by Ted Beason about Plaintiff's job duties RESPONSE: None in the City’s possession. 32. All documents reflecting all communications between Ted Beason and Jack McLean regarding Plaintiff. RESPONSE: See the City’s response to requests No. 2 and 20 above. 33. All documents identifying all persons hired by Defendant under Jack McLean’s direct and/or indirect supervision during the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents identifying every person the City has hired while Jack McLean has been City Manager in the past 6 years are not relevant to Plaintiff's claims or the City’s defenses in this case. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. 34. All documents identifying all persons terminated by Defendant under Jack McLean’s direct and/or indirect supervision during the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents identifying every person the City has terminated while Jack McLean has been City Manager are not relevant to Plaintiff's claims or the City’s defenses in this case. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. 35. All documents identifying all positions that have been eliminated under the direct and/or indirect supervision of Jack McLean, Ted Beason, Angela Gran-Sapp, Keith Dowdell and Ronte Harris.RESPONSE: The City produces the City budgets for 2015-2021, which list the City’s personnel positions every budget year, see Exhibit 3. 36. All proposed and enacted organizational charts for Defendant for the time period covered by this request. RESPONSE: See Exhibit 4. 37. All documents discussing position eliminations, downsizing and/or a reduction in force during the time period covered by this request. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents discussing downsizing, a reduction in force, or the elimination of any position in the 6-year span of this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. Additionally, see the City’s responses to Request Nos. 2 and 20 above. 38. All documents and job descriptions showing all positions considered to be a supervisor position under Jack McLean’s direct and/or indirect supervision during the time periodcovered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents and job descriptions showing all positions considered to be a supervisor position under Jack McLean's direct and/or indirect supervision during the time period covered herein are not relevant to Plaintiff's claims or the City’s defenses in this matter. Subject to and without waiving this objection, the City provides the policies defining the Exempt Executive Employee positions that are exempt from the Career Service employment appeal provisions of the Personnel Rules and Regulations, which are City Personnel Policies, 1.03 and 1.04, and the job descriptions for those positions. See Exhibits 5 and 6. 39. All meeting minutes, notes, audio recordings, and/or agendas of all staff meetings held for the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All meeting minutes, notes, audio recordings, and/or agendas of all staff meetings held for the 6-year time period under this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not stored in a reasonably accessible, centralized location. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving theissues in this matter. 40. All minutes for all City Council/Commission meetings of Defendant for the time period January 1, 2017 to date. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All minutes for all City Council/Commission meetings of Defendant for the time period January 1, 2017 to date are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, these documents are equally available to Plaintiff on the City’s website, avaliable at: http://www.myaquincy.net/i/appointed- officials/city-clerk/commission-agendas-2. 41. All documents including without limitation emails and proposed and enacted organizational charts reflecting communications between Defendant, Jack McLean, Ted Beason, Maria Francis, Ann Sherman and/or any and/or all other persons pertaining to position eliminations, sick leave, evaluations, department reorganizations and employee terminations for the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents reflecting all communications between Defendant, Jack McLean, Ted Beason, Maria Francis, Ann Sherman and/or any and/or all other persons pertaining to position eliminations, sick leave, evaluations, department reorganizations and employee terminations for every City employee for the 6-year time span covered herein, regardless of whether these documents are related to Plaintiff or her claims in any way, are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not stored in a reasonably accessible, centralized location. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. Additionally, see the City’s responses to Request Nos. 2 and 20 above. 42. All emails between Defendant, Ted Beason, Maria Francis, Ann Sherman, Vancheria Perkins and Jack McLean pertaining to Plaintiff's job duties and coverage while she was on leave. RESPONSE: See the City’s response to Request Nos. 2 and 20 above. 43. All meeting minutes, notes, audio recordings and/or documents produced during all staff and City Commission/Council meetings held on or around August 2018. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All meeting minutes, notes, audio recordings and/or documents produced during all staff and City Commission/Council meetings held on or around August 2018 are not relevant to Plaintiffs claims or the City’s defenses in this matter. Additionally, the agendas and minutes for these meetings are equally available toPlaintiff on the City’s website, avaliable at: http://www.myaquincy.net/i/appointed- officials/city-clerk/commission-agendas-2. 44. All organizational charts for City of Quincy that were in place during Plaintiff's employment and for the time period covered herein. RESPONSE: As for organizational Charts for the City that were in place during Plaintiff's employment, none in the City’s possession. As for any organizational charts that were in place during the time period covered herein, see Exhibit 4. 45. All budgets for Defendant for each year covered by this request. RESPONSE: See Exhibit 3. 46. All documents that Defendant relies on to support any and/or all claims that Plaintiff's position was eliminated. RESPONSE: None in the City’s possession. 47. All documents upon which Defendant relies to show that Defendant had a budget shortfall that resulted in the elimination of Plaintiff's position and/or otherwise adversely affectedPlaintiff’s position. RESPONSE: None in the City’s possession. 48. All budget documents identifying all persons who lost their jobs and/or were adversely affected by budget shortfalls. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. Additionally, Plaintiffs requested time span is overbroad and seeks documents completely unrelated to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. 49. All documents that identifying all persons whose positions were eliminated in calendar years 2017, 2018, 2019 and 2020. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents that identifying all persons whose positions were eliminated in calendar years 2017, 2018, 2019 and 2020 are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production ofthese documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. Subject to and without waiving this objection, the City produces the City budgets for the requested years, which lists the City’s positions for each year. See Exhibit 3. 50. All policies, procedures, rules and regulations that were applicable to Plaintiff's employment with Defendant including without limitation such documents relating to Defendant's hiring process, disciplinary process, termination, leave (paid, unpaid and FMLA), predetermination hearings, disability accommodations (ADA), and Defendant’s grievance process. RESPONSE: See City Personnel Handbook, Exhibit 5. 51. All emails showing all communication between the following persons regarding the ELWP: Plaintiff, Marvin Bailey, Yolanda Hernandez, Shelby Jefferson, David Worthington, Kim Hodges, Nana Gatlin, and/or Linda Williams. RESPONSE: The City is unaware of the identities of these individuals. 52. All documents identifying all accommodations that Defendant provided to Plaintiff during the time period covered by this request. RESPONSE: The City objects to this request because it Is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery to the extent it seeks documents related to any accommodations, such as sick leave, the City provided to Plaintiff for various medical conditions while she was employed with the City. To the extent that this request seeks documents identifying all accommodations that Defendant provided to Plaintiff for the alleged disability she claims in this case, see Exhibit 1-A. 53. All documents showing that it would have been an unreasonable hardship on defendant to accommodate Plaintiff. RESPONSE: Without Plaintiff identifying the accommodation Plaintiff requested, the City is unable to respond to this request. 54. All documents identifying all accommodations provided to all current and/or former employees of Defendant for the time period covered by this request. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents identifying all accommodations provided to all current and/or former employees of Defendant for the time period covered by this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Plaintiff's requested time span is overbroad and seeks documents completely unrelated to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonablyaccessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the Issues in this matter. 55. All documents Defendant received related to Plaintiff disability and accommodations for returning to work. RESPONSE: See Exhibit 1-A for documents related to Plaintiff's claimed disability and doctor’s note for returning to work. Otherwise, none in the City’s possession. 56. All documents that Francis, Beason, Sherman, McLean, Dowdell, created about Plaintiff during the time period covered by this request. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents that Francis, Beason, Sherman, McLean, Dowdell, created about Plaintiff in the 6-year time span covered by this request are not relevant to Plaintiffs claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. Additionally, this request seeks documents protected by the attorney client and work product privileges. Additionally, see the City’s response to Request Nos. 2 and 20 above. Subject to and without waiving these objections, see Exhibits 1-A and 2. 57. All documents that contain any and/or all discussions of Plaintiff's requested accommodations and/or time off work that she submitted on or around July 9, 2018. RESPONSE: See the City’s response to Requests No. 2 and 20 above. Otherwise, none in the City’s possession. 58. All documents that discuss and/or set forth the reason that on or around July 9,2018, Plaintiff's job position was eliminated. RESPONSE: None in the City’s possession. 59. All documents that discuss Plaintiff's evaluations during the time period covered by this request. RESPONSE: None in the City’s possession. 60. All emails that Plaintiff sent to Defendant and any supervisor and/or coworker regarding the workload and stress level of the position she held for the time covered by this requesthere in.RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All emails that Plaintiff sent to Defendant and any supervisor and/or coworker regarding the workload and stress level of the position she held for the 6- year period covered by this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Plaintiff claims disability discrimination based on pain in her neck. E-mails that are purely concerning her workload and stress level are not relevant to her claims. Additionally, this information is not reasonably accessible because it is not stored in a centralized location that is accessible to the City, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. Additionally, see the City’s response to Request Nos. 2 and 20 above. 61. All emails that Plaintiff sent to Defendant regarding her leave, medical condition and accommodations for returning to work. RESPONSE: The City objects to this request because Plaintiff's former employee e-mail account is not reasonably accessible to the City due to undue burden. Additionally, see the City’s response to Request Nos. 2 and 20 above. 62. All evaluations prepared on or about Ted Beason, Ann Sherman and Maria Francisduring the time period covered by this request for all employees under their supervision. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All evaluations prepared on or about Ted Beason, Ann Sherman and Maria Francis during the time period covered by this request for all employees under their supervision are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location that is accessible to the City, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. Subject to and without waiving these objections, see Exhibits 1-B and 1-K. 63. All evaluations prepared on or about Plaintiff during the entire course of her employment with Defendant. RESPONSE: See Exhibit 1-A. 64. All documents that Defendant prepared and submitted to the Florida Commission on Human Relations (FCHR) and/or EEOC in response to all charges of discrimination and/or retaliation filed by Plaintiff. RESPONSE: The City objects to this request to this request because It seeks informationprotected by the work-product privilege. 65. All documents that were authored by and/or at the direction of Jack McLean aboutand/or regarding Plaintiff. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents that were authored by and/or at the direction of Jack McLean about and/or regarding Plaintiff in the 6-year time span covered by this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. Subject to and without waiving this objection, See Exhibits 1-A, 2, and 3. 66. All documents showing all responses to Plaintiffs application and/or request for sick leave in or around April 2018. RESPONSE: See Exhibit 1-A. 67. Alldocuments created about and/or regarding Plaintiff including without limitation documents about Plaintiff's request for workplace accommodations. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents created about and/or regarding Plaintiff in the 6-year time span covered by this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. See the City’s response to Request Nos. 2, 20, and 22 above. 68. — All documents in which Defendant discussed Plaintiff's position elimination on or around July 9, 2018. RESPONSE: None in the City’s possession. 69. All documents created by and/or at the direction of Jack McLean about and/or regarding Plaintiff. RESPONSE: See the City’s response to request number 65 above. 70. All documents received or created by Defendant’s human resources officepersonnel that reference Plaintiff. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents received or created by Defendant’s human resources office personnel that reference Plaintiff in the 6-year time span covered by this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. Subject to and without waiving these objections, see Exhibit 1-A. 71. All documents that reference and/or support Plaintiff's July 2018 termination. RESPONSE: See Exhibit 1-A and 2. 72. All documents that were created by Ted Beason and/or Jack McLean and/or any employee about allegations of customer complaints that implicate and/or discuss Plaintiff. RESPONSE: _ See the City’s response to Request No. 2 above. Otherwise, none in the City’s possession. 73. Alldocuments that were provided to Defendant’s Human Resources about Plaintiff. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents provided to the Human Resources Department at any time for the 6-year period covered by this request are not relevant to Plaintiff's claims or the City defenses in this matter. Subject to and without waiving this objection. See Exhibit 1-A. 74. All documents showing all communications including without limitation emails, between any and all of Defendant’s employees that reference Plaintiff. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents showing all communications including without limitation emails, between any and all of Defendant's employees that reference Plaintiff in any way for the 6-year time span covered by this request are not relevant to Plaintiffs claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present an undue burden to the City. The e-mail accounts of former employee are not reasonably accessible to the City due to undue burden. The burden orexpense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. The City also objects to this request because it seeks documents protected by the attorney-client privilege. See the City’s response to Request Nos. 2 and 20 above. Subject to and without waiving these objections, see Exhibit 2. 75. — All emails and documents authored by Plaintiff about her termination and position elimination. RESPONSE: See Exhibit 7 and the City’s response to Request No. 61 above. 76. ~All emails between Plaintiff and Defendant during the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All emails between Plaintiff and Defendant discussing any topic for the 6-year time span covered by this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. See the City’s response to Request Nos. 2, 20, and 61 above. 77. All documents that identify all persons under the supervision of Jack McLean during the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documents that identify all persons under the supervision of Jack McLean during the 6-year time span covered by this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not stored in a reasonably accessible, centralized location. The burden or expense to the City to locate and produce this discovery outweighs its likely benefit, considering the needs of the case and the importance of these documents in resolving the issues in this matter. 78. All rules, regulations, policies and procedures regarding employee evaluations and/or FMLA leave during the time period covered herein. RESPONSE: See Exhibit 5. 79. All documentation showing any and/or all complaints filed against Jack McLean during the time period covered herein. RESPONSE: The City objects to this request because it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. This request seeks documents outside the scope of discovery. All documentation showing any and/or all complaints filed against Jack McLean during the 6-year time span covered by this request are not relevant to Plaintiff's claims or the City’s defenses in this matter. Additionally, this information is not reasonably accessible because it is not stored in a centralized location, so production of these documents would present