Preview
Filing # 130344714 E-Filed 07/09/2021 12:03:21 PM
IN THE CIRCUIT COURT OF THE
SECOND JUDICIAL CIRCUIT, IN AND
FOR GADSDEN COUNTY, FLORIDA
CATHERINE ROBINSON,
ve
Plaintiff,
CASE NO.: 2020-CA-000859
CITY OF QUINCY,
Defendant.
SSS
FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF
FROM DEFENDANT CITY OF QUINCY
Pursuant to Rule 1.350, Florida Rules of Civil Procedure, Defendant CITY OF QUINCY
(“City”) hereby requests that Plaintiff CATHERINE ROBINSON produce for inspection and
copying at a mutually agreeable location, the following listed documents within thirty (30) days
after service of this request in accordance with the instructions in “Exhibit A.”
DOCUMENTS TO BE PRODUCED
Copies of all documents or statements submitted to or received from the EEOC or FCHR
related your employment with Defendant.
All documents pertaining to your employment with the City.
All accolades or awards related to your employment received during your employment
with the City.
All documents supporting your allegation that during your employment with Defendant,
you had an actual disability, perceived disability, or record of impairment.
All documents showing that while you were employed with the City, the City knew you
had an actual disability, perceived disability, or record of impairment.
All documents showing that while you were employed by the City, you requested an
accommodation and/or assistance from the City due to your disability.
All documents supporting your allegation that during your employment with Defendant,
you were subjected to disparate treatment, different terms and conditions of your10.
41.
12.
13.
14.
15.
16.
17.
18.
19.
employment, and/or were held to a different standard because your disability,
perceived disability, or record of impairment.
All documents supporting your allegation that during your employment with Defendant,
you were subjected to retaliation because you reported unlawful employment activities
and criminal conduct.
All documents supporting your allegation that you have suffered an adverse
employment action because of your disability, perceived disability, or record of
impairment.
All documents showing the existence of non-disabled employees who were similarly
situated to yourself and received more favorable treatment from Defendant.
All documentation supporting your contention that you were able to perform the
essential functions of the job with reasonable accommodations.
All documentation supporting your allegation in paragraph 7 of your Complaint that you
had stellar work performance during your employment with the City.
All documentation supporting your allegation in paragraph 7 of your Complaint that
Plaintiff has been subjected to disparate treatment, different terms and conditions of
employment, and was held to a different standard because of her actual or perceived
disability and record of impairment.
All documentation supporting your allegation in paragraph 7 of your Complaint that
Plaintiff reported Defendant’s unlawful employment activities and was subject to
retaliation thereafter.
All documentation supporting your allegation in paragraph 8 of your Complaint that the
disparate treatment and retaliation came at the hand of specifically but not limited to
City Manager Jack McLean, Mayor Angela Grant-Sapp, Commissioner Keith Dowdell,
and Commissioner Ronte Harris. Please describe with specificity how each individual
allegedly retaliated against you or treated you with disparate treatment.
All photographs, drawings, or videos that support or undermine the factual assertions
in your Complaint.
All emails or text messages sent or received by you which relate to or reference the
factual allegations in your complaint or your physical, or emotional state or wellbeing.
Any and all documents received from the City or from any present or former employee
of the City that are related to the allegations in the Complaint.
Any and all correspondence between you and any present or former employee of the
City related to the allegations in the Complaint, including e-mails, text messages, etc.
4852-6120-9583, v. 120.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
Any and all documents identified by you, relied upon in responding to, or used by you
in your answers to Defendant’s First Set of Interrogatories.
Any and all statements, affidavits, depositions, audio/video recordings, or transcripts
of any witnesses to any of the events alleged in the Complaint in your possession or
the possession of your attorneys or agents.
Any and all of your personal notes, calendars, diaries, journals, chronicles computer
records, e-mail messages, letters, memoranda, inter-office correspondence, notes, or
other items prepared by or on behalf of plaintiff which relate to or reflect the incidents
or episodes that gave rise to any of plaintiff's complaints in the instant lawsuit,
including any and all notes from any interactions or meetings with any of Defendant’s
employees, agents or representatives.
Any and all documents relating to any treatment, examination or consultation by any
healthcare or other professional (e.g., doctors, nurses, psychiatrists, psychologists,
counselors, therapists, clergy members, etc.) for r all isability.
Any and all documents relating to any treatment, examination or consultation by any
healthcare or other professional (e.g., doctors, nurses, psychiatrists, psychologists,
counselors, therapists, clergy members, etc.) for any condition in the past five years.
Any and all documents relating to any treatment, examination or consultation by any
healthcare or other professional (e.g., doctors, nurses, psychiatrists, psychologists,
counselors, therapists, clergy members, etc.) for the damages alleged in your
Complaint.
Any documents relevant to any claim of liability or damages in this case that you
received from any third party either before or during the pendency of this lawsuit.
Any and all of your social network postings (e.g., Facebook, Myspace, blogging, Twitter,
LinkedIn) that relate to or reflect the factual allegations in your complaint or your claim
for damages.
All documentation supporting any damages you claim you incurred as a result of the
allegations in your complaint.
Copies of any salary, hourly, or contract payments you have received from any person
or employer since July 9, 2018.
All documentation supporting your contention that you suffered past and future lost
wages, loss of benefits, and other tangible and pecuniary damages.
Any and all applications for employment with any employer since July 9, 2018.
Any and all documents comprising, demonstrating, or referencing any job offers since
July 9, 2018.
4852-6120-9583, v. 133. Copies of invoices for any other expenses or costs you allege were incurred as a result
of the allegations in the Amended Complaint.
34. Any document not encompassed by one of the requests above which you intend to use
to support your claims in this case.
35. ~~ Allist or log of all documents that are being withheld from production by virtue of any
privilege of non-production or for any other reason. For each such document, please
carefully follow the Instructions above and list the document by its name, date, author,
and recipient and specify the reason for withholding it from production.
Respectfully submitted this 9th day of July 2021.
4s William G. Pafford
Gwendolyn Adkins, (FBN: 0949566)
OWI William G. Pafford, (FBN: 99594)
~ gadkins@coppinsmonroe.com
CO)BBINSE woatford@coppinsmonroe.com
WON C15 jclark@coppinsmonroe.com
adelk@coppinsmonroe.com
CopPiNs MONROE, P.A.
1319 Thomaswood Drive, Tallahassee, FL 32308
Office: 850-422-2420 | Fax: 850-422-2730
ATTORNEYS FOR DEFENDANT
CITY OF QUINCY
CERTIFICATE OF SERVICE
This document is being filed electronically through the Florida Courts eFiling Portal;
Pursuant to Rule 2.516, Fla. R. Jud. Admin., electronic service will be made by the Court’s
transmission facilities on all persons appearing before this Court.
sf Wiliam G. do
Attorney
4852-6120-9583, v. 1“Exhibit A”
When used in this Request for Production of Documents, the following words shall have
the following meanings:
4. "Document", unless otherwise specified, means and includes every written,
typed, printed, recorded or graphic matter, however produced or reproduced, of any kind and
description, including, but not limited to, all papers, notes, drafts, accounts, books,
correspondence, cablegrams, telegrams, memoranda, letters, reports, studies, analyses,
pamphlets, calculations, projections, drawings, specifications, contracts, graphs, charts,
agreements, working papers, records, books of account, journals, ledgers, notebooks,
vouchers, bank checks, cashier's checks, receipts for cashier's checks, canceled checks,
check stubs, budgets, statements, bills, receipts, invoices, desk calendars, appointment
books, diaries, logs, transcriptions, audio or video recordings of any conversation, discussions,
negotiation, meeting or conference, conducted in person or via any electronic medium, and
things similar to any of the foregoing containing information, however denominated or
described. "Documents" further means such documents as are in your possession, custody or
control, whether made, written or prepared by you or by any other person. “Documents”
further means any such documents that are stored on any kind of electronic storage1.
"Documents" further means the original of such documents or if the original is not in your
possession, custody or control, then such copy as is in your possession, custody or control. If
only part of the original or a copy of any requested document is in your possession, custody
or control, then identify such part of the document as is in your possession, custody or control.
1 The term “electronic storage” shall be interpreted as defined in 18 U.S.C. § 2510(17)
(2004).2. "And" as well as "or" shall be construed either disjunctively or conjunctively as
necessary to bring within the scope of this production request any information which might
otherwise be construed to be outside its scope.
3. "Related to" or "relating to" means concerning, respecting, referring to,
embodying, including, identified with, connected with, in conjunction with, evidencing,
representing or comprising.
4. "You" or "Your" means the Plaintiff and/or any of her attorneys, agents or
representatives.
5. As used in this request, and unless indicated to the contrary, the relevant time
period for this request shall be from January 1, 2013, until the present time.
INSTRUCTION:
1. Any document as to which a claim of privilege is or will be asserted should
include the identity of author, signatory, description (e.g., letter, memorandum, telex,
recording, etc.), title (if any), date, addresses (if any), general subject matter, present
depository and present custodian and a complete statement of the ground for the claim of
privilege should be set forth.
2. If it is maintained that any document which is requested has been destroyed,
set forth the contents of the document, the date of such destruction and the name of the
person who authorized, directed, and/or participated in such destruction.
3. If any of the documents cannot be produced in full, produce to the extent
possible, specifying the reasons for the inability to produce the remainder.
4852-6120-9583, v. 1
Preview
Filing # 130344714 E-Filed 07/09/2021 12:03:21 PM IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT, IN AND FOR GADSDEN COUNTY, FLORIDA CATHERINE ROBINSON, ve Plaintiff, CASE NO.: 2020-CA-000859 CITY OF QUINCY, Defendant. SSS FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF FROM DEFENDANT CITY OF QUINCY Pursuant to Rule 1.350, Florida Rules of Civil Procedure, Defendant CITY OF QUINCY (“City”) hereby requests that Plaintiff CATHERINE ROBINSON produce for inspection and copying at a mutually agreeable location, the following listed documents within thirty (30) days after service of this request in accordance with the instructions in “Exhibit A.” DOCUMENTS TO BE PRODUCED Copies of all documents or statements submitted to or received from the EEOC or FCHR related your employment with Defendant. All documents pertaining to your employment with the City. All accolades or awards related to your employment received during your employment with the City. All documents supporting your allegation that during your employment with Defendant, you had an actual disability, perceived disability, or record of impairment. All documents showing that while you were employed with the City, the City knew you had an actual disability, perceived disability, or record of impairment. All documents showing that while you were employed by the City, you requested an accommodation and/or assistance from the City due to your disability. All documents supporting your allegation that during your employment with Defendant, you were subjected to disparate treatment, different terms and conditions of your10. 41. 12. 13. 14. 15. 16. 17. 18. 19. employment, and/or were held to a different standard because your disability, perceived disability, or record of impairment. All documents supporting your allegation that during your employment with Defendant, you were subjected to retaliation because you reported unlawful employment activities and criminal conduct. All documents supporting your allegation that you have suffered an adverse employment action because of your disability, perceived disability, or record of impairment. All documents showing the existence of non-disabled employees who were similarly situated to yourself and received more favorable treatment from Defendant. All documentation supporting your contention that you were able to perform the essential functions of the job with reasonable accommodations. All documentation supporting your allegation in paragraph 7 of your Complaint that you had stellar work performance during your employment with the City. All documentation supporting your allegation in paragraph 7 of your Complaint that Plaintiff has been subjected to disparate treatment, different terms and conditions of employment, and was held to a different standard because of her actual or perceived disability and record of impairment. All documentation supporting your allegation in paragraph 7 of your Complaint that Plaintiff reported Defendant’s unlawful employment activities and was subject to retaliation thereafter. All documentation supporting your allegation in paragraph 8 of your Complaint that the disparate treatment and retaliation came at the hand of specifically but not limited to City Manager Jack McLean, Mayor Angela Grant-Sapp, Commissioner Keith Dowdell, and Commissioner Ronte Harris. Please describe with specificity how each individual allegedly retaliated against you or treated you with disparate treatment. All photographs, drawings, or videos that support or undermine the factual assertions in your Complaint. All emails or text messages sent or received by you which relate to or reference the factual allegations in your complaint or your physical, or emotional state or wellbeing. Any and all documents received from the City or from any present or former employee of the City that are related to the allegations in the Complaint. Any and all correspondence between you and any present or former employee of the City related to the allegations in the Complaint, including e-mails, text messages, etc. 4852-6120-9583, v. 120. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. Any and all documents identified by you, relied upon in responding to, or used by you in your answers to Defendant’s First Set of Interrogatories. Any and all statements, affidavits, depositions, audio/video recordings, or transcripts of any witnesses to any of the events alleged in the Complaint in your possession or the possession of your attorneys or agents. Any and all of your personal notes, calendars, diaries, journals, chronicles computer records, e-mail messages, letters, memoranda, inter-office correspondence, notes, or other items prepared by or on behalf of plaintiff which relate to or reflect the incidents or episodes that gave rise to any of plaintiff's complaints in the instant lawsuit, including any and all notes from any interactions or meetings with any of Defendant’s employees, agents or representatives. Any and all documents relating to any treatment, examination or consultation by any healthcare or other professional (e.g., doctors, nurses, psychiatrists, psychologists, counselors, therapists, clergy members, etc.) for r all isability. Any and all documents relating to any treatment, examination or consultation by any healthcare or other professional (e.g., doctors, nurses, psychiatrists, psychologists, counselors, therapists, clergy members, etc.) for any condition in the past five years. Any and all documents relating to any treatment, examination or consultation by any healthcare or other professional (e.g., doctors, nurses, psychiatrists, psychologists, counselors, therapists, clergy members, etc.) for the damages alleged in your Complaint. Any documents relevant to any claim of liability or damages in this case that you received from any third party either before or during the pendency of this lawsuit. Any and all of your social network postings (e.g., Facebook, Myspace, blogging, Twitter, LinkedIn) that relate to or reflect the factual allegations in your complaint or your claim for damages. All documentation supporting any damages you claim you incurred as a result of the allegations in your complaint. Copies of any salary, hourly, or contract payments you have received from any person or employer since July 9, 2018. All documentation supporting your contention that you suffered past and future lost wages, loss of benefits, and other tangible and pecuniary damages. Any and all applications for employment with any employer since July 9, 2018. Any and all documents comprising, demonstrating, or referencing any job offers since July 9, 2018. 4852-6120-9583, v. 133. Copies of invoices for any other expenses or costs you allege were incurred as a result of the allegations in the Amended Complaint. 34. Any document not encompassed by one of the requests above which you intend to use to support your claims in this case. 35. ~~ Allist or log of all documents that are being withheld from production by virtue of any privilege of non-production or for any other reason. For each such document, please carefully follow the Instructions above and list the document by its name, date, author, and recipient and specify the reason for withholding it from production. Respectfully submitted this 9th day of July 2021. 4s William G. Pafford Gwendolyn Adkins, (FBN: 0949566) OWI William G. Pafford, (FBN: 99594) ~ gadkins@coppinsmonroe.com CO)BBINSE woatford@coppinsmonroe.com WON C15 jclark@coppinsmonroe.com adelk@coppinsmonroe.com CopPiNs MONROE, P.A. 1319 Thomaswood Drive, Tallahassee, FL 32308 Office: 850-422-2420 | Fax: 850-422-2730 ATTORNEYS FOR DEFENDANT CITY OF QUINCY CERTIFICATE OF SERVICE This document is being filed electronically through the Florida Courts eFiling Portal; Pursuant to Rule 2.516, Fla. R. Jud. Admin., electronic service will be made by the Court’s transmission facilities on all persons appearing before this Court. sf Wiliam G. do Attorney 4852-6120-9583, v. 1“Exhibit A” When used in this Request for Production of Documents, the following words shall have the following meanings: 4. "Document", unless otherwise specified, means and includes every written, typed, printed, recorded or graphic matter, however produced or reproduced, of any kind and description, including, but not limited to, all papers, notes, drafts, accounts, books, correspondence, cablegrams, telegrams, memoranda, letters, reports, studies, analyses, pamphlets, calculations, projections, drawings, specifications, contracts, graphs, charts, agreements, working papers, records, books of account, journals, ledgers, notebooks, vouchers, bank checks, cashier's checks, receipts for cashier's checks, canceled checks, check stubs, budgets, statements, bills, receipts, invoices, desk calendars, appointment books, diaries, logs, transcriptions, audio or video recordings of any conversation, discussions, negotiation, meeting or conference, conducted in person or via any electronic medium, and things similar to any of the foregoing containing information, however denominated or described. "Documents" further means such documents as are in your possession, custody or control, whether made, written or prepared by you or by any other person. “Documents” further means any such documents that are stored on any kind of electronic storage1. "Documents" further means the original of such documents or if the original is not in your possession, custody or control, then such copy as is in your possession, custody or control. If only part of the original or a copy of any requested document is in your possession, custody or control, then identify such part of the document as is in your possession, custody or control. 1 The term “electronic storage” shall be interpreted as defined in 18 U.S.C. § 2510(17) (2004).2. "And" as well as "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of this production request any information which might otherwise be construed to be outside its scope. 3. "Related to" or "relating to" means concerning, respecting, referring to, embodying, including, identified with, connected with, in conjunction with, evidencing, representing or comprising. 4. "You" or "Your" means the Plaintiff and/or any of her attorneys, agents or representatives. 5. As used in this request, and unless indicated to the contrary, the relevant time period for this request shall be from January 1, 2013, until the present time. INSTRUCTION: 1. Any document as to which a claim of privilege is or will be asserted should include the identity of author, signatory, description (e.g., letter, memorandum, telex, recording, etc.), title (if any), date, addresses (if any), general subject matter, present depository and present custodian and a complete statement of the ground for the claim of privilege should be set forth. 2. If it is maintained that any document which is requested has been destroyed, set forth the contents of the document, the date of such destruction and the name of the person who authorized, directed, and/or participated in such destruction. 3. If any of the documents cannot be produced in full, produce to the extent possible, specifying the reasons for the inability to produce the remainder. 4852-6120-9583, v. 1