Interrogatories

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					                 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
                      MUNICIPAL DEPARTMENT, FIRST DISTRICT


METROPLEX, INC.,                                   )
                                                   )
                     Plaintiff,                    )
                                                   )
                     v.                            )      No. 02 M1 707520
                                                   )
JAMES THORTON,                                     )
                                                   )
                     Defendant.                    )


                   DEFENDANT'S INTERROGATORIES TO PLAINTIFF


       Now comes the defendant, JAMES THORTON, by and through his attorneys, the


Legal Assistance Foundation of Metropolitan Chicago, and pursuant to Rule 213 of the


Illinois Supreme Court, requests that Plaintiff answer the following interrogatories on or


before June 21, 2002.


                                  Definitions and Instructions


       "Defendant" means James Thorton.


       "Plaintiff," "you" or "your", unless otherwise stated, means Metroplex, Inc., its


agents, representatives, attorneys, etc.
       "Premises" means 1365 North Hudson Street, #484, Chicago, Illinois.


       "Including" means including but not limited to.


       When asked to identify an individual, please provide that individual's name,


current address, and current telephone number.


       A. In answering these interrogatories, you are required to furnish all information


which is available to you, including information in the possession of your agents,


representatives or any organization acting on your behalf.


       B.     If you cannot answer any of the following interrogatories in full, after


exercising due diligence to secure the information to do so, answer to the extent possible


and specify the reason for your inability to furnish a complete answer.


       C.     Each interrogatory calls not only for your knowledge, but also for all


knowledge that is available to you through reasonable inquiry, including inquiry of your


representative(s) or agent(s).


       D.     Pursuant to Rule 213(i) of the Illinois Supreme Court, you must seasonably


supplement or amend your answers whenever you discover new or additional information.
       E.     If you withhold information, based on a claim that such information is


privileged, you must (1) state the exact nature of the privilege your are claiming, and (2)


support your claim by describing the nature of the information you are withholding.


                             I N T E R R O G A T O R I E S


       1.     What is the full name, address, telephone number, title and/or position of


the individual(s) answering these interrogatories?


       2.     When did Defendant move into the premises?


       3.     Pursuant to what specific program is Defendant’s tenancy subsidized?


       4.     Does Defendant’s subsidy run with the premises?


       5.     Is Defendant’s lease agreement automatically renewed at the end of every


lease term unless it is terminated for good cause?


       6.     What is Defendant’s share of the monthly rent?


       7.     When did you last accept Defendant’s rent?


       8.     With respect to the allegation contained in your termination notice dated


March 8, 2002 (a copy of which is attached to these interrogatories), that “[o]n


                                            3
03/04/02 at approximately 7:45 AM [Defendant was] verbally abusive to a tenant and


two Security Officers and [Defendant] threatened to physically assault the Security Officer,


resulting in [Defendant’s] arrest for simple assault,” please:


              a)     identify (by name, address, and telephone number) the tenant to


                     whom Defendant was allegedly verbally abusive;


              b)     state what Defendant allegedly said to this tenant;


              c)     identify (by name, address and telephone number) the two security


                     officers to whom Defendant was allegedly verbally abusive;


              d)     state what Defendant allegedly said to these security officers;


              e)     identify the security officer Defendant allegedly threatened;


              f)     describe Defendant’s threat;


              g)     identify (by name, badge number, and precinct) each and every


                     police officer who participated in Defendant’s arrest;


              h)     state when and where the arrest took place;


              i)     identify the individual(s) who called the police; and


                                            4
              j)      identify (by name, address, and telephone number) each and every


                      person who saw or heard Defendant engage in the activity described


                      in your termination notice.


       9.     Was Defendant current in his rent when you issued the termination notice


dated March 8, 2002?


       10.    If the answer to interrogatory 9 is “no,” please state exactly how much rent


Defendant owed.


       11.    Furnish the identity and location of each and every witness who will testify at


trial on Plaintiff's behalf, and describe the subject of each witness's testimony.




                                                                         Lawrence D. Wood
                                            One of Defendant's Attorney




Lawrence D. Wood
Jessica Kalmewicki


                                             5
Legal Assistance Foundation of Metropolitan Chicago
1279 North Milwaukee Avenue, #407
Chicago, Illinois 60622
Tel: 773/572-3222 Fax: 773/572-3201
Attorney No. 91012




                                          6
                IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
                     MUNICIPAL DEPARTMENT, FIRST DISTRICT


METROPLEX, INC.,                                 )
                                                 )
                    Plaintiff,                   )
                                                 )
                    v.                           )      No. 02 M1 707520
                                                 )
JAMES THORTON,                                   )
                                                 )
                    Defendant.                   )




                                 CERTIFICATE OF SERVICE


      I, Jessica Kalmewicki, one of the defendant's attorneys, certify that I hand-delivered
a copy of the attached discovery requests to Robert Kahn (Plaintiff’s attorney) at
180 North LaSalle Street, Suite 2025, Chicago, Illinois 60601, before the close of
business on May 24, 2002.




                                          One of Defendant's Attorney




Lawrence D. Wood/Jessica Kalmewicki
LEGAL ASSISTANCE FOUNDATION OF METROPOLITAN CHICAGO
1279 North Milwaukee Avenue, #407
Chicago, Illinois 60622
Tel: 773/572-3222 Fax: 773/572-3201
Attorney No. 91012

				
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