TO: Plaintiff Weltee Wolo through her counsel, Tyler W. Brennan, Tyler W. Brennan Law,
LLC, T3 Building, 323 N. Washington Avenue, Suite 200, Minneapolis, MN 55401.
Pursuant to Rule 34 of the Minnesota Rules of Civil Procedure, Defendant Whispering
Pines Assisted Living, Inc. (“Whispering Pines” or “Defendant”) requests that Plaintiff Weltee
Wolo (“Wolo” or “Plaintiff”) produce and permit Whispering Pines to inspect and copy the
following documents, electronically stored information, and things, within thirty (30) days of the
date of service hereof.
In responding to the following requests, unless the context indicates otherwise, you are to
construe them in light of the following:
DEFINITIONS
1. The term “Document” shall have the broadest meaning which can be ascribed to it
pursuant to Rule 26 of the Minnesota Rules of Civil Procedure. Among other things, the term
“Document” refers to and includes any written, printed, typed or other graphic matter of any kind
or nature, all computer materials, processes, data and compilations thereof from which information
can be obtained, including, but not limited to, papers, letters, correspondence, telegrams, inter-
STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF ANOKA TENTH JUDICIAL DISTRICT
Case Type: Employment
Weltee Wolo,
Plaintiff,
vs.
Whispering Pines Assisted Living, Inc.,
Defendant.
Court File No.
The Honorable
DEFENDANT’S REQUESTS FOR
PRODUCTION OF DOCUMENTS TO
PLAINTIFF (SET I)
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office communications, memoranda, notes, notations, notebooks, reports, records, minutes of
meetings, schedules, tables, charges, transcripts, publications, scrapbooks, diaries, E-mail,
electronic mail, voice mail, electronic bulletin board postings, tabulations, vouchers, accounts,
statements, affidavits, abstracts, agreements, contracts, diaries, calendars, plans, specifications,
drawings, sketches, photostats, photographs, charts, graphs and other similar objects, and any kind
of transcript, transcription or recording of any conversation, discussion or oral presentation of any
kind, and any information stored on, and reproducible in documentary form from a computer or
other electronic, magnetic, optical or laser based information storage device, including but not
limited to floppy disks, hard disks, tapes, backup tapes, CD-ROM, DVD’s, USB drives, thumb
drives, external data storage devices, handheld PC’s, or PDA’s and any drafts, revisions or
amendments of the above, in the possession or within the control of Plaintiff, her attorneys or
agents, or known by Plaintiff to exist, including materials deemed to be subject to any evidentiary
privilege. The term “Document” specifically includes Electronically Stored Information.
2. “Electronically Stored Information” or “ESI” shall include all electronic
information permitted to be discovered under Rule 34 of the Minnesota Rules of Civil Procedure,
including, without limitation: Internet web pages, word-processing documents, spreadsheets,
presentation documents, graphics, animations, images, email (including attachments which shall
be kept with the email), instant messages, text messages, voice mail, audio, video, and audiovisual
recordings, databases and database subsets, and other user or machine-created computer files or
other digital information which is stored on computer networks, servers, computer systems,
desktop computers, laptop computers, home computers, the Internet, an Intranet, archives, discs,
CD’s, diskettes, drives, zip drives, tapes, cartridges, flash drives, and other external storage media,
personal digital assistants, handheld wireless devices, smart phones, cellular telephones,
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blackberries, pagers, iPhones, iPads, iPods, and voicemail systems. All of the ESI requested herein
shall be produced with all metadata preserved.
3. The term “Communications” means all forms of oral, written, and nonverbal
communication, including, but not limited to, communications taking place face-to-face, via
telephone, facsimile, electronic mail, voice mail, electronic messaging (e.g., instant messaging),
or by means of correspondence, letters, statements, or otherwise.
4. The term “Person” refers to and includes natural persons, corporations,
partnerships, proprietorships, joint ventures, unincorporated associations, trusts, estates,
governments (and agencies thereof), quasi-public entities, and other forms of legal entities.
5. The terms “reflecting,” “concerning,” “evidencing,” “referred to,” “related to,”
“regarding,” “depicted,” or “displayed” mean and include, without limitation, regarding, showing,
reflecting, referring to, alluding to, responding to, relating to, connected with, commenting upon,
with respect to, consisting of, comprising, constituting, discussing, recording, or in any way
touching upon or pertaining to.
6. The singular form of a word shall also refer to the plural, and words used in the
masculine, feminine, or neuter gender shall refer to and include all genders.
7. “And” includes the disjunctive “or”; “or” includes the conjunctive “and.”
8. “Defendant,” “Whispering Pines,” or “WPAL” shall refer to Whispering Pines
Assisted Living, Inc., as well as its agents, attorneys, or anyone acting or purporting to act on its
behalf.
9. “You” or “Your” shall refer to Plaintiff Weltee Wolo, as well as her agents,
attorneys, or anyone acting or purporting to act on her behalf.
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10. “Plaintiff” or “Wolo” shall refer to Plaintiff Weltee Wolo, as well as her agents,
attorneys, or anyone acting or purporting to act on her behalf.
11. “Complaint” shall mean the Complaint filed and served by Plaintiff in the above-
captioned matter, and any subsequent amendments thereto.
12. “Answer” shall mean the Answer served by Defendant in the above-captioned
matter, and any subsequent amendments thereto.
DOCUMENT-SPECIFIC INSTRUCTIONS
13. You are requested and required to produce each Document designated below that
is within your care, custody, or control or otherwise available, including Documents in the
possession of your attorneys, accountants, advisors, or other persons directly or indirectly acting
for you or with you. If all Documents requested cannot be produced in their entirety, produce each
Document requested to the extent possible, specify the reason for the inability to produce the
remaining Documents, and state whatever information or knowledge you have regarding the
unproduced Documents. If you maintain that any Document has been destroyed, set forth the
contents of the Document, the location of any copies of the Document, the date of and reason for
such destruction, and the name and address of all persons who ordered, authorized, or participated
in such destruction.
14. If any Document is withheld from production on the basis of privilege or otherwise,
identify each such Document and the grounds upon which production of each Document is being
withheld. Include:
(a) the date;
(b) the author;
(c) the type of Document;
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(d) the addressee(s) or other intended recipient(s);
(e) the title, heading, or other designation numerical on the Document; and
(f) the privilege type and basis for the privilege.
15. These Requests shall be deemed continuing so as to require supplemental responses
if ACA obtains further information between the times responses are served and the time of trial.
REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: All Documents and Communications that You referred to, relied
upon, consulted, or used in any way to draft the Complaint, Your Initial Disclosures, and/or Your
responses to Defendant’s First Set of Interrogatories to Plaintiff.
REQUEST NO. 2: All Documents and Communications relating to, referring to,
supporting, and/or refuting any of the allegations in the Complaint.
REQUEST NO. 3: All Documents and Communications relating to, referring to,
supporting, and/or refuting the allegation that Defendant failed to pay You for Your accrued,
unused vacation time, as set forth in paragraphs 9 and 35–38 of the Complaint.
REQUEST NO. 4: All Documents and Communications relating to, referring to,
supporting, and/or refuting the allegation that Defendant’s stated reason for terminating You is a
mere pretext for discrimination and reprisal and/or has no factual basis, as set forth in paragraphs
14–15 of the Complaint.
REQUEST NO. 5: All Documents and Communications relating to, referring to,
supporting, and/or refuting the allegation that Defendant failed to pay You earned wages within
24 hours of Your demand, as set forth in paragraphs 19 and 31–34 of the Complaint.
REQUEST NO. 6: All Documents and Communications relating to, referring to,
supporting, and/or refuting the allegation that Defendant’s decision to terminate Your employment
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otherwise occurred under circumstances that give rise to an inference of unlawful discrimination,
as set forth in paragraphs 20–24 of the Complaint.
REQUEST NO. 7: All Documents and Communications relating to, referring to,
supporting, and/or refuting the allegation that Defendant took adverse actions against You in
reprisal to activity protected under MHRA, as set forth in paragraphs 25–30 of the Complaint.
REQUEST NO. 8: All Documents and Communications relating to, referring to,
supporting, and/or refuting your allegation that other employees of Defendant were similarly
situated to You, but treated more favorably than You, as set forth in paragraphs 25–30 of the
Complaint.
REQUEST NO. 9: All Documents and Communications relating to, referring to, and/or
reflecting any and all complaints of any kind that You allege to have made to Defendant at any
time.
REQUEST NO. 10: All Documents and Communications relating to, referring to, and/or
reflecting any and all reports of discrimination and/or reprisal that You allege to have made to
Defendant at any time.
REQUEST NO. 11: Journals, diaries, calendars, appointment books, agendas,
notebooks, and notes written or maintained by You from 2018 through and including the present
relating to or referring to any of the allegations in the Complaint and/or Your employment with
Defendant.
REQUEST NO. 12: All Documents and Communications relating to Your employment
with Whispering Pines Assisted Living, Inc. and any change in Your employment status, job
duties, promotions, and/or job transfers, including but not limited to all contracts, agreements,
memoranda, policies, handbooks, complaints filed, performance reviews, performance
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improvement plans, warnings, disciplinary actions, termination notices, resignation letters, and
reports that are related to any of the allegations in the Complaint.
REQUEST NO. 13: All Documents that are the property of Whispering Pines Assisted
Living, Inc. or that you removed or directed to be removed from Whispering Pines Assisted Living,
Inc.’s premises, including but not limited to its physical premises and computer systems.
REQUEST NO. 14: All Documents relating to, referring to, supporting, and/or refuting
the alleged discriminatory culture which existed in the workplace, as alleged in paragraph 12 of
the Complaint.
REQUEST NO. 15: All Documents and Communications submitted to or received from,
the U.S. Equal Employment Opportunity Commission (EEOC), the Minnesota Department of
Human Rights (MDHR), and/or the Minnesota Department of Employment and Economic
Development (DEED), including but not limited to documents relating to any charges of
discrimination and/or applications for unemployment benefits that You have made since 2016.
REQUEST NO. 16: All Documents and Communications relating to any administrative
charge or proceeding or lawsuit to which You were a party within the last ten years relating to
Your employment with any Employer that rely on or are similar or related to the factual allegations
or claims at issue in this lawsuit.
REQUEST NO. 17: All Documents and Communications relating to any complaint of
harassment, discrimination, or retaliation that you alleged against any employer within the last ten
years.
REQUEST NO. 18: All Documents and Communications relating to Your efforts to seek
employment from December 11, 2020, through and including the present, including but not limited
to any resumes, applications for employment, cover letters, reference letters, job inquiries, offers
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of employment, employment agreements, independent contractor and consulting agreements or
arrangements, job advertisements or postings, rejection letters, and any other communications with
any Employer.
REQUEST NO. 19: All Documents and Communications relating to the termination of
Your employment from any Employer, whether voluntary or involuntary, occurring at any time
after the end of Your employment with Whispering Pines Assisted Living, Inc.
REQUEST NO. 20: All Documents and Communications relating to any training or
education that You have applied for or received from December 11, 2020, through and including
the present.
REQUEST NO. 21: Documents sufficient to show any income or other compensation
received by or owed to You, including but not limited to paychecks, paystubs, invoices, settlement
payments, statements of work, Form W-2s, Form 1099s, social security benefits, social security
disability benefits, unemployment insurance benefits, workers’ compensation benefits, and long-
term or short-term disability benefits from December 11, 2020, through and including the present.
REQUEST NO. 22: Your federal and state income tax returns for the tax years 2020
through and including the present, including all supporting documentation.
REQUEST NO. 23: All Documents and Communications relating to, referring to,
supporting, and/or refuting Your claim for damages in this lawsuit, including but not limited to
documents relating to the claim for damages as set forth in paragraphs 20–38 of the Complaint,
your initial disclosures, and/or the calculation of damages claimed.
REQUEST NO. 24: All Documents and Communications relating to, referring to,
supporting, and/or refuting any injuries, including physical, mental, and emotional injuries, You
allegedly sustained as a result of Whispering Pines Assisted Living, Inc.’s conduct from 2018
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through and including the present, including but not limited to all medical records and
psychotherapy notes.
REQUEST NO. 25: Completed and executed authorization forms for the release of
medical records and psychotherapy notes for each physician, psychiatrist, psychologist, therapist,
social worker, or other healthcare professional identified in response to Interrogatory Number 11
of Defendant’s First Set of Interrogatories to Plaintiff with whom You have consulted and/or from
whom You have received or sought treatment.
REQUEST NO. 26: All Documents and Communications relating to and/or referring to
each expert you intend to call as a witness at trial, including but not limited to all Documents and
Communications sent to or received from each expert, resumes, curriculum vitae, and reports.
REQUEST NO. 27: All affidavits, sworn statements, notes, and other documents sent to,
received from, or otherwise relating to any person you intend to call as a witness at trial, either in
person, through deposition testimony, or through an affidavit regarding, referring, and/or relating
to any claim or allegation in this Action.
REQUEST NO. 28: All affidavits, sworn statements, and communications regarding,
referring, and/or relating to any claim in this Action.
REQUEST NO. 29: All social media postings relating to any of the allegations in the
Complaint, including but not limited to postings on Facebook, LinkedIn, Twitter, YouTube,
Instagram, Snapchat, TikTok, blogs, wikis, and other social media sites.
REQUEST NO. 30: All Documents and Communications that contain or otherwise relate
to facts that you contend refute, in any way, any of Defendant’s defenses in this Action.
REQUEST NO. 31: A complete copy of all the Facebook information from January 1,
2018, to the present, for any Facebook account currently or previously maintained by You. You
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can download a complete copy of such information by logging into each applicable Facebook
account, choosing “Settings & Privacy,” choosing “Settings,” choosing “Your Facebook
Information,” and then choosing “Download Your Information.” On the “Download Your
Information” page, you can then select the date range of January 1, 2018 to the present, selecting
a Media Quality of “High” or “Medium,” and selecting “HTML” as the Format before clicking
“Create File.”
REQUEST NO. 32: All Documents identified in Section 2 of Your Initial Disclosures.
Dated: November 19, 2021 SPENCER FANE LLP
By: /s/ Randi J. Winter
Randi J. Winter, #0391354
Jose A. Castro, #0399696
100 South Fifth Street, Suite 2500
Minneapolis, MN 55402
Telephone: (612) 268-7000
Facsimile: (612) 268-7001
rwinter@spencerfane.com
Attorneys for Defendant Whispering Pines Assisted
Living, Inc
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