When I counted my seven and a half hours of typed answers yesterday to the interrogatories the District’s lawyers fired at me it didn’t occur to me to subtract the words in the questions themselves. (I would never have had the time to do this before word counters.) There were a lot of words in the 28 questions, 1,288 to be exact. I finished answering the questions today and edited the lot once. Normally, I’d want to edit something like this several times.
After subtracting the words in the interrogatories it turned out that my answers totaled 8,220 words. That would equal eleven of the DNT’s Point-of-View columns.
The taxpayer’s attorney made no edits and offered no editing suggestions. He’s never discouraged me from writing anything in this blog either. He seems so unconcerned about what I’ve written I almost wonder if he bothered to read it. I’ll ask him tomorrow morning when I go over to meet with him and sign my answers officially for the court.
I was prepared to alter my answers if he thought they might antagonize or irritate the judge or weaken our case. Craig Hunter’s attitude is refreshing. He simply wants this client to honestly answer the questions the way I see fit. I’ll post my answers tomorrow but for now here are the questions they asked each plaintiff.
ANSWERS TO DEFENDANT JOHNSON CONTROLS, INC.’S INTERROGATORIES TO PLAINTIFF HARRY R. WELTY (SET I)
The plaintiff Harry R. Welty answers set I of Defendant Johnson Controls, Inc.’s interrogatories as follows:
Interrogatory No. 1: Identify all Persons you believe have knowledge of any fact that is relevant to the claims or defenses in this litigation, and for each such person, describe in detail the knowledge you believe such person has.
Answer:
Interrogatory No. 2: Identify all Persons you believe have knowledge of JCI’s business relationship with the School District and School Board, and for each such person, describe in detail the knowledge you believe such person has.
Answer:
Interrogatory No. 3: Identify and describe in detail any and all Communications and Meetings you have had with any School Board member (including but not limited to Gary Glass), School District agent or employee, or JCI agent or employee related to the RFP; the Response; the Agreement; the Resolution; or any issues relating to the subject matter of this litigation.
Answer:
Interrogatory No. 4: Identify and describe in detail any and all Statements in your possession or that you are aware of referring to or related to the RFP; the Response; the Agreement; the Resolution; or any issues related to the subject matter of this litigation.
Answer:
Interrogatory No. 5: Identify all Persons you believe have knowledge of the School District’s policies and practices with respect to the procurement of professional services or for the procurement of goods, and for each such person, describe in detail the knowledge you believe such person has.
Answer:
Interrogatory No. 6: Identify all Persons you believe have knowledge of the School District’s selection process with respect to the specific proposals submitted in response to the RFP, and for each such person, describe in detail the knowledge you believe such person has.
Answer:
Interrogatory No. 7: Identify all Persons you believe had knowledge of JCI’s preparation and submission of its Response to the RFP, and for each such person, describe in detail the knowledge you believe such person has.
Answer:
Interrogatory No. 8: Identify all Persons you believe had knowledge of the negotiation and execution of the Agreement, and for each such person, describe in detail the knowledge you believe such person has.
Answer:
Interrogatory No. 9: Identify all Persons you believe have knowledge of the School Board’s adoption of the Resolution, and for each such person, describe in detail the knowledge you believe such person has.
Answer:
Interrogatory No. 10: Describe in detail the factual basis of your assertion in Paragraph 14 of your Complaint that “the amount yet to be spent on the red plan is hundreds of millions of dollars.”
Answer:
Interrogatory No. 11: Describe in detail the factual basis of your assertion in Paragraph 14 of you Complaint that “the fees yet to be generated to Johnson Controls for professional services related to the “red plan”, may run to tens of millions of dollars.”
Answer:
Interrogatory No. 12: Identify and describe in detail any and all Documents or Statements in your possess or that you are aware of related to the RFP; the School District’s selection process and criteria with respect to the RFP; the School District’s selection of JCI’s Response; the negotiation and execution of the Agreement; or the School Boards adoption of the Resolution. Your response does not need to include documents in the St. Louis County Court File regarding this litigation.
Answer:
Interrogatory No. 13: Identify any and all Documents, Communications, and Statements dated January 1, 2005 to present, in which you have expressed your opinions regarding the School District, the School Board; individual School Board members, the RFP; JCI; the Response, the Agreement; the Resolution; or the “red plan.”
Answer:
Interrogatory No. 14: Identify and describe all activities in which you have participated in addition to this lawsuit to oppose to the RFP; the Agreement; the Resolution; or the “red plan.”
Answer:
Interrogatory No. 15: Describe in detail the “Let Duluth Vote” campaign, including but not limited to the date the campaign was established; the Persons who established the campaign; any and all Persons who have held positions within the campaign; any and all Persons who currently hold positions within the campaign; the date the website www.letduluthvote.com was established; any and all Persons who update material on the website www.letduluthvote.com; any and all activities in which the campaign participates; and any and all efforts and activities in which the “Let Duluth Vote campaign has participated in opposition to the RFP; the Agreement; or the Resolution.
Answer:
Interrogatory No. 16: Identify all Persons whom you believe have knowledge or information regarding the profits JCI will earn as a result of the Agreement and for each such person, describe in detail the knowledge you believe such person has.
Answer:
Interrogatory No. 17: Describe in detail when you first received any information regarding the RFP including what information you received; the source of that information; how you received the information; and when you received the information.
Answer:
Interrogatory No. 18: Describe in detail when you first received any information regarding the Response, including what information you received; the source of that information; how you received the information; and when you received the information.
Answer:
Interrogatory No. 19: Describe in detail when you first received any information regarding the School Board’s selection of JCI following the issuance of the RFP, including what information you received; the source of that information; how you received the information; and when you received the information.
Answer:
Interrogatory No. 20: Describe in detail when you first received any information regarding the Agreement, including what information you received; the source of that information; how you received the information; and when you received the information.
Answer:
Interrogatory No. 21: Describe in detail when you first received any information regarding the Resolution, including what information you received; the source of that information; how you received the information; and when you received the information.
Answer:
Interrogatory No. 22: Describe in detail the letter referenced in a posting by Plaintiff Harry R. Welty on www.lincolndemocrat.com on May 20, 2008 which “outlined a possible case of bid rigging by Johnson Controls” including but not limited to the letter’s author; the party to whom the letter is addressed; the letter’s date; how you came into possession of the letter; and the letter’s contents.
Answer:
Interrogatory No. 23: Identify all Persons you believe have knowledge or information with respect to the veracity of the allegations asserted on www.lincolndemocrat.com, www.snowbizzs.com and www.letduluthvote.com that JCI influenced the School Board’s RFP selection process in its favor, and describe in detail the knowledge or information you believe such person has.
Answer:
Interrogatory No. 24: Identify any and all documents, Communications and Statements relating to, referring to or evidencing the veracity of the allegations asserted on www.lincolndemocrat.com, www.snowbizz.com and www.letduluthvote.com that JCI influenced the School Board’s RFP selection process in its favor.
Answer:
Interrogatory No. 25: Describe in detail your relationship with each of the current School Board members, including Gary Glass, including but not limited to any Communications referring or relating to the issues in this lawsuit; the RFP; the Response; the Agreement; or the “red plan.”
Answer:
Interrogatory No. 26: Identify all Persons whom you believe have knowledge or information with respect to the veracity of your allegation that JCI induced the School District entered into an unlawful contract and describe in detail the knowledge or information you believe such person has.
Answer:
Interrogatory No. 27: Identify an all personal e-mail addresses you have used from period beginning January 1, 2006 to the present.
Answer:
Interrogatory No. 28: Identify any and all personal computers you have used from the period beginning January 1, 2006 to the present.
Answer:
I’ve been chomping at the bit to answer these questions for several weeks now but our attorney believes in doing first things first. That meant raising a hundred grand. My chance to submit my answers to the court was almost all the incentive I needed to raise that money.
Ah the money! I’ll collect that from Craig Hunter tomorrow and turn it into a surety bond.
