Defendant’s Interrogatory to Plaintiff #15:
State whether the plaintiff(s) or plaintiff(s) attorney have the means of possessing any writing, document, statement, letter, record, or other pertinent information that relates to the alleged debris or foreign object which precipitated the plaintiff(s) fall. If so, identify the item, the date of its acquisition, the source of its acquisition and the means of its acquisition.Plaintiff’s Answer to Interrogatory #15: :
Counsel believes that documents or other items are stored under lock and key in the corporate headquarters of the Defendant. Plaintiff’s counsel is looking to retain the services of Howard Hunt, Gordon Liddy and James McCord to properly assess the most exacting and efficient way to ‘have the means of possessing’ said items. As to if and when Plaintiff’s counsel (or our agents) obtain said items, Plaintiff objects on the grounds that it would call for disclosure of attorney work product and that it would violate the constitutional right to be free from self-incrimination. That said, Investigation continues.It would be nice if discovery actually allowed for a sense of humor.