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HomeMy WebLinkAboutHDC1993-005 Letter Form City Of Little Rock To Mr. William W. Hylton, III 06//17//1994City of Little Rock Thomas M. Carpenter City Attorney June 17, 1994 Mr. William W. Hylton, III Attorney at Law 1501 South Elm Street Little Rock, AR 72204 City Hall 500 W. Markham St. Little Rock, AR 72201-1400 501/371-4527 Re: Duffey, et al. v. City of Little Rock, et al. U.S.D.C. No. LR-C-94-344 Dear Mr. Hylton: Enclosed please find the City's First Set of Interrogatories and Requests for'Production of Documents to the Plaintiffs. If you have any questions, please feel free to contact me. Sincerely, Thomas M. Carpenter City Att r ' y By: Stephen R. Giles Deputy City Attorney TMC:SRG:td Enclosure 0 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION EVELYN DUFFEY AND ALISON PATTON V. NO. LR-C-94-344 CITY OF LITTLE ROCK, ARKANSAS AND THE QUAPAW QUARTER ASSOCIATION PLAINTIFFS DEFENDANTS SEPARATE DEFENDANT CITY OF LITTLE'ROCK'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS PROPOUNDED TO THE PLAINTIFFS The City of Little Rock propounds its first set of Interrogatories and Requests for Production of Documents to the Plaintiffs. [All paragraph references below, unless otherwise indicated, are to the Amended Complaint filed on May 3, 1994. All references to the "property", unless otherwise indicated, are to 815 South Rock Street, Little Rock, AR described in the Amended Complaint.] INTERROGATORY NO. 1: Please state the name of all parties participating in the preparation of responses to these Interrogatories, their current address and telephone number. INTERROGATORY NO. 2: Please identify all persons who have knowledge of the facts alleged or described in the Complaint, Amended Complaint or other pleadings filed herein, pertaining to any of the facts relevant or material to the issues in this case. INTERROGATORY NO. 3: For each such person identified in Interrogatory No. 2, please state briefly the substance and extent of their knowledge, giving their name, current address and work and residence telephone numbers. ,J� INTERROGATORY NO. 4: Please state the name, address, work and residence telephone number of each and every individual you intend to call at the trial of this matter, stating whether the person will be called as a lay or expert witness, and provide a brief summary of the substance of the testimony expected of the witness. INTERROGATORY No. 5: With regard to Paragraph 14, please state specifically any and all actions taken by or for the Plaintiffs to secure the property from entry by children or any other persons, stating the cost incurred by the Plaintiff or others on their behalf, and whether any such security measures were in place on the property upon the filing of this lawsuit or today. INTERROGATORY NO. 6: With regard to Paragraph 15, please provide the names, addresses and telephone numbers of the realtors which Plaintiffs allege to have sought to market the property. INTERROGATORY No. 7: With regard to Paragraph 21, describe what economically beneficial use the Plaintiffs intended of the property had they been allowed to demolish it. INTERROGATORY No. 8: With regard to Paragraph 21, describe specifically all of the economically beneficial uses of the property which the City is alleged to have deprived the Plaintiffs. INTERROGATORY NO. 9: With regard to Paragraph 30, please describe all out-of-pocket expenses alleged to have been incurred by the Plaintiffs. INTERROGATORY No. 10: With regard to Paragraph 31, the Plaintiffs claim, among other things, that they fear their -2- exposure to liability to innocent third parties on the property. Please describe specifically what active measures Plaintiffs have taken to reduce the risk of injury to persons entering the property, and whether those safety measures are in place today. INTERROGATORY NO. 11: Please give the current address of the Plaintiffs, and if different from the current address, the the date and address of the Plaintiffs when the acquired title to 815 South Rock Street. Also describe the proximity of the Plaintiffs' residence to the property. INTERROGATORY No. 12: Please state the assessed value of the property and whether the Plaintiff's have contested or objected to the assessment by Pulaski County. INTERROGATORY NO. 13: Please treat these Interrogatories - and Requests for Production of Documents as continuing and furnish to the City, in writing, any additional information received by you subsequent to the date of your answers hereto which would modify or supplement you answers, such additional information to be furnished as soon as reasonably possible after receipt by you and within a reasonable time prior to the assigned trial or hearing date in --order to permit appropriate discovery procedure. Will you do so- REQUESTS FOR PRODUCTION OF DOCUMENTS "Produce" means to furnish legible copies to the City Attorney within the time specified by the Federal Rules of Civil Procedure or, alternatively, to make available to the City Attorney the originals (or legible copies) under circumstances where photocopying at a reasonable expense to the City can be facilitated. 0 -3- RE UEST FOR PRODUCTION NO. 2: Please identify and produce copies of all documents you intend to offer at the trial of this matter, and any other non -privileged documents which you do not intend to produce at trial, but which might form a basis for the Plaintiffs' allegations. REQUEST FOR PRODUCTION No. 2: Please provide copies of each and every listing agreement, contract for purchase and sale, title reports, deeds, mortgages, certificates or other evidence of insurance, tax assessments or'documents evidencing your challenge to the tax assessment, regarding the property. REQUEST FOR PRODUCTION NO. 3: Please provide copies of cancelled checks, invoices, work orders, receipts, or any other documentation evidencing the Plaintiffs expenses incurred in rehabilitating and maintaining the structure and grounds at 815 South Rock Street. • REQUEST FOR PRODUCTION NO. 4: With regard to Paragraphs 30 through 37, please provide copies of all documentation you intend to introduce to support your claim for damages in this action. Respectfully submitted, Thomas M. Carpenter City t rney By: p en i es, o. Deputy City Attorney City Hall - Room 310 500 West Markham Little Rock, AR 72201 (501) 371-4527 0 -4- CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been served upon William W. Hylton, III, Attorney at Law, 1501 South Elm Street, Little Rock, AR 72204, Y_,pacing same in the U.S. mail, postage prepaid, on thisday of June, 1994. G Stephen, Gx es -5-