Color of Law Abuse by the Saint Louis Metropolitan Police Department: Answer to Interrogatories by OladimejiAlade

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									                             MISSOURI CIRCUIT COURT
                          TWENTY-SECOND JUDICIAL CIRCUIT
                                  (ST. LOUIS CITY)

OLADIMEJI JACOBS ALADE and                           )
TAIWO ALADE,                                         )
                                                     )
                                   Plaintiffs,       )     Cause No. 1222-CC01246
                                                     )
v.                                                   )      Division 11
                                                     )
METROPOLITAN POLICE DEPARTMENT,                      )
CITY OF ST. LOUIS                                    )
                                                     )
And                                                  )
                                                     )
JOHN DOES 1-3                                        )
                                                     )
                                   Defendants.       )


         PLAINTIFF, CAPT. DR. TAIWO ALADE’S ANSWERS TO DEFENDANTS’
                               INTERROGATORIES

     AND NOW COMES the Plaintiff, Capt. Dr. Oladimeji Jacobs Alade by and through

Counsel, Henry Eslter, Esq., and pursuant to MO. Rule 57.01(a) files this response to

Defendants’ Interrogatories as follows:


                       NOTES, EXCEPTION AND EXPLANATIONS

   (a) The information supplied in these answers is not based solely on the knowledge of the
executive party, but includes the knowledge of the party and his attorney, unless privileged.

    (b) The word usage in sentence structures may be that of the attorney assisting in the
preparation of these Answers, and thus do not necessarily purport to be the precise language of
the executing party.
                           ANSWERS TO INTERROGATORIES

Interrogatory No. 1: With respect to the items described on the two pages titled “Metropolitan

Police Department – City of St. Louis Property Receipt,” state which items you claim to own.




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Answer to Interrogatory No. 1: All the properties ceased by the Metropolitan Police
Department – City of St. Louis on February 2, 2012 (seven days after Capt. Dr. Alade filed a
complaint against Barnes Jewish Hospital) as described, are marital properties as defined under
V.A.M.S. § 452.330(b); accordingly all the properties belong to both Capt., Dr. Oladimeji Alade
and Dr. Taiwo Alade.

Interrogatory No. 2: If you claim to be the owner of the item described on the “Metropolitan

Police Department – City of St. Louis Property Receipt” as “Sony Vaio laptop SID 54128833,”

then state the following:

               a. Identify the manufacturer of the encryption software on the item;

               b. State the type of encryption software on the item;

               c. State the password that enables the encryption to provide access to the item.

Answer to Interrogatory No. 2: The claim of ownership is on the basis of Answer to
Interrogatory No. 1. In further answer, Plaintiffs object to Interrogatory No. 2 insofar as it
purports to compel the Plaintiff to disclose information protected under the United States
Constitution. Accordingly, at the advice of counsel, Plaintiff invokes her Fifth Amendment rights
as articulated by the United States Supreme Court in United States v. Hubbell, 530 U.S. 27, 120
S.Ct. 2037, 147 L.Ed.2d 24 (2000) and all its progenies.


Interrogatory No. 3: If you claim to be the owner of the item described on the “Metropolitan

Police Department – City of St. Louis Property Receipt” as “Asus K52F laptop SID

ABN0BC00846P488,” then state the following:

               d. Identify the manufacturer of the encryption software on the item;

               e. State the type of encryption software on the item;

               f. State the password that enables the encryption to provide access to the item.

Answer to Interrogatory No. 3: The claim of ownership is on the basis of Answer to
Interrogatory No. 1. In further answer, Plaintiffs object to Interrogatory No. 3 insofar as it
purports to compel the Plaintiff to disclose information protected under the United States
Constitution. Accordingly, at the advice of counsel, Plaintiff invokes her Fifth Amendment rights
as articulated by the United States Supreme Court in United States v. Hubbell, 530 U.S. 27, 120
S.Ct. 2037, 147 L.Ed.2d 24 (2000) and all its progenies.




                                                2
Interrogatory No. 4: If you claim to be the owner of the external hard drive device described on

the “Metropolitan Police Department – City of St. Louis Property Receipt” as

“WCAWZ0988097,” then state the following:

              a.      Identify the manufacturer of the encryption software on the device;

              b.      State the type of encryption software on the device;

              c.      State the password that enables the encryption to provide access.

Answer to Interrogatory No. 4: The claim of ownership is on the basis of Answer to
Interrogatory No. 1. In further answer, Plaintiffs object to Interrogatory No. 4 insofar as it
purports to compel the Plaintiff to disclose information protected under the United States
Constitution. Accordingly, at the advice of counsel, Plaintiff invokes her Fifth Amendment rights
as articulated by the United States Supreme Court in United States v. Hubbell, 530 U.S. 27, 120
S.Ct. 2037, 147 L.Ed.2d 24 (2000) and all its progenies.


                                     Respectfully submitted,



                                     /s/ Henry P. Elster________________________
                                     Henry P. Elster, #62875MO
                                     7750 Clayton Road, Suite 102
                                     Saint Louis, Missouri 63117
                                     (314) 283-8930 (Telephone)
                                     (314) 645-7901 (Facsimile)
                                     henry@elsterlaw.com (E-mail)




                                               3
                                      SWORN STATEMENT

STATE OF MISSOURI             )
                              ) SS
CITY OF ST. LOUIS             )

       Oladimeji Jacobs Alade, being duly sworn upon his oath, states that he is the party to

whom the foregoing interrogatories are directed, and that the answers given are true to the best of

his knowledge and belief.




                                                     ____________________________________


       Subscribed and sworn to before me this ____ day of ________, 2012.

My Commission Expires:



______________________                               ______________________________
                                                     Notary Public




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