UNITED STATES DISTRCT COURT WESTERN DISTRICT OF NEW YORK _______________________________________ SHELLONNEE B. CHINN, Plaintiff, vs.
THE ELMWOOD FRANKLIN SCHOOL, et al.
PLAINTIFF’S REQUESTS FOR THE PRODUCTION OF DOCUMENTS FROM DEFENDANTS THE ELMWOOD FRANKLIN SCHOOL. Docket No.: 15-cv-0938-FPG-JJM
Defendants. _______________________________________
PLAINTIFF REQUESTS FOR THE PRODUCTION OF DOCUMENTS The following are documents requested from the Elmwood Franklin School (Buffalo, NY) in a racial discrimination and civil rights lawsuit now pending in federal court in Buffalo. Under Rules 26 and 34 of the Federal Rules of Civil Procedure plaintiff is entitled to these documents and Elmwood Franklin has an obligation to turn them over to her.
Volume 1 Requests dated April 5 -9, 2018
Plaintiff’s Requests for Production of Documents from the Elmwood Franklin School
NOTICE The attached documents are formal requests for defendants in a federal lawsuit to produce and turn over documents in their custody to the plaintiff. The documents requested include complete employee records, student academic records, insurance policies, tax returns, minutes of Board meetings, etc. Once delivered to plaintiff, these documents will be used in the litigation and care will be taken to protect the privacy of any records of students. There are approximately 30 defendants in this case associated with the Elmwood Franklin School. They are: The Elmwood Franklin School, Andrew Deyell, Sarah Duddy, Alyssa Schwabe, Patti Scaffidi, Molly Clauss, Jenna Evaldi, Michele Kulpit, Michael Joseph, Alice Jacobs, Barry Heneghan, Catherine Beltz-Foley, Cyndi Burnett, Christopher Koch, Omar Kahn, Brian J. Lipke, Alon Kupferman, Kimisha Brown Houston, Cutler Greene, Arthur Glick, Keith Frome, Scott Friedman, Terri Rich, Peter Allen Weinmann, Nicholas B. Tzetzo, Sonja Siren, Robert Scott, Anthony Johnson, and Michele Lee.
RULE 26(a)(1)(A)(iv) FRCP Document Request 1. As mandated by Rule 26(a)(1)(A)(iv) FRCP, plaintiff requests a copy of any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment in this action or to indemnify or reimburse for payments made to satisfy judgment for each and every one of the following defendants: The Elmwood Franklin School, Andrew Deyell, Sarah Duddy, Alyssa Schwabe, Patti Scaffidi, Molly Clauss, Jenna Evaldi, Michele Kulpit, Michael Joseph, Alice Jacobs, Barry Heneghan, Catherine Beltz-Foley, Cyndi Burnett, Christopher Koch, Omar Kahn, Brian J. Lipke, Alon Kupferman, Kimisha Brown Houston, Cutler Greene, Arthur Glick, Keith Frome, Scott Friedman, Terri Rich, Peter Allen Weinmann, Nicholas B. Tzetzo, Sonja Siren, Robert Scott, Anthony Johnson, and Michele Lee. Request dated: April 5, 2018 -EndRespectfully, /s/ Shellonnee B. Chinn _______________________________ Shellonnee B. Chinn, Plaintiff
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Plaintiff’s RULE 26(a)(1)(A)(iv) FRCP Document Request
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Documents Requested Request #1: A copy of complete employee file or record of any and all employee(s) (including Sarah Duddy who was terminated and reinstated) of The Elmwood Franklin School whose employment at The Elmwood Franklin School ended, for any reason, between September 1, 2012 and April 1, 2018. Request #2: A copy of minutes of staff meetings of the administrative team/staff of The Elmwood Franklin School (usually held mornings/weekly) from September 1, 2012 to April 1, 2018. Request #3: Copy of resume, or other listing, of complete educational history and employment history of each of the following: Andrew Deyell, Sarah Duddy, Alyssa Schwabe, Patti Scaffidi, Molly Clauss, Jenna Evaldi, Michele Kulpit, Michael Joseph, Alice Jacobs, Barry Heneghan, Catherine Beltz-Foley, Cyndi Burnett, Christopher Koch, Omar Kahn, Brian J. Lipke, Alon Kupferman, Kimisha Brown Houston, Cutler Greene, Arthur Glick, Keith Frome, Scott Friedman, Terri Rich, Peter Allen Weinmann, Nicholas B. Tzetzo, Sonja Siren, Robert Scott, Anthony Johnson, and Michele Lee. Request dated: April 5, 2018 -EndRespectfully, /s/ Shellonnee B. Chinn _______________________________ Shellonnee B. Chinn, Plaintiff
Plaintiff’s First Request for Production of Documents Upon Defendants The Elmwood Franklin School, et al
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Documents Requested Request #1: A copy of complete employee file of every person employed at the Defendant Elmwood Franklin School, including salary histories, from January 1, 2013 to April 1, 2018. (This request does not include those Defendant Elmwood Franklin School employees whose employee records have been requested under Request #1 of Document Request dated April 5, 2018.) Request #2: A copy of all minutes, notes, or correspondences of Elmwood Franklin School Board of Trustees meetings, including any minutes or notes of Executive Session meetings or committee meetings or sub-committee meetings, held between September 1, 2012 and April 1, 2018. Request #3: A copy of annual student/parent/school handbook from January 1, 2001 to April 1, 2018. Request #4: A copy of employee manual or handbook of Defendant Elmwood Franklin School, with any amendments, governing from September 1, 2001 to April 1, 2018. Request #5: A copy of annual tax returns, including all schedules, for Defendant Elmwood Franklin School for tax periods 2012 to 2017. Request #6: A copy of any letter, complaint, request for information or other communication from any local, state or federal government agency inquiring or investigating compliance, or possible violation of, any local, state or federal law, rule, or regulation.
Request dated: April 7, 2018 -End-
Plaintiff’s Second Request for Production of Documents Upon Defendants The Elmwood Franklin School, et al
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Documents Requested
Request #1: A copy of ELA and Math assessment test scores (for Fall and Spring exams) for each and every student enrolled in Prep I to 8th grade at the Defendant Elmwood Franklin School for tests administered between September 1, 2011 and April 1, 2018, with the name of student and regardless of current enrollment status of student. Request #2: A copy of ERB scores for each and every student enrolled in grades 3 to 8 at the Defendant Elmwood Franklin School for tests administered between September 1, 2011 and April 1, 2018, with the name of student and regardless of current enrollment of student. Request #3: A list of any other diagnostic test(s) administered at Defendant Elmwood Franklin School between September 1, 2011 and April 1, 2018 to students enrolled in Prep I to 8th grade.
Request dated: April 9, 2018 -EndRespectfully, /s/ Shellonnee B. Chinn _______________________________ Shellonnee B. Chinn, Plaintiff
Plaintiff’s Third Request for Production of Documents Upon Defendants The Elmwood Franklin School, et al
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