Bear in mind the District has given the taxpayers squat for discovery. Here’s what they are demanding of us:
Oh, and this is the easy part. You should see the instructions that came with this. They were five pages long.
The plaintiff Harry R. Welty responds to set I of Defendant Johnson Controls, Inc.’s request for production of documents as follows:
Request No. 1: All Documents, Communications or Statements referred to in your responses to JCI’s Interrogatories to Plaintiff Harry R. Welty (Set I).
Response:
Request No. 2: All Documents, Communications, or Statements related to or referencing JCI in connection with the issues raised in this litigation, including but not limited to JCI’s Response, the School Board’s selection of JCI’s Response or the “red plan.”
Response:
Request No. 3: All documents, Communications, or Statements related to, referring to, or evidencing the School Board’s adoption of the Resolution.
Response:
Request No. 4: All Documents, Communications, or Statements related to, referring to, or evidencing 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.”
Response:
Request No. 5: All Documents, Communications, or Statement related to, referring to, or evidencing your assertion in Paragraph 14 of your 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.”
Response:
Request No. 6: All Documents, Communications, or Statements related to, referring to, or evidencing any Communications and Meetings you have had with any School Board member (including but not limited to Gary Glass); School District agent or employee; JCI agent or employee or any other party related to the issues in this lawsuit, including but not limited to the RFP; the School District’s selection process and criteria with respect to the RFP; the School District’s selection of the JCI’s Response; the negotiation and execution of the Agreement; the School Board’s adoption of the Resolution ; or the “red plan.”
Response:
Request No. 7: All documents, relating to, referring to, or evidencing JCI’s relationship and interactions with the School District and School Board between January 4, 2006 and January 27, 2007.
Response:
Request No. 8: All Documents evidencing material that is currently, or has ever been, posted on the websites http://www.lincolndemocrat.com, http://www.snowbizz.com, or http://www.letdulduthvote.com relating to the issues in this lawsuit; JCI; the RFP; the Response; the Agreement; the Resolution; or the “red plan.”
Response:
Request No. 9: All documents evidencing material Plaintiffs have posted to any social networking websites including, but not limited to Facebook and Myspace relating to the issues in this lawsuit; JCI; the RFP; the Response; the Agreement; the Resolution; or the “red plan.”
Response:
Request No. 10: Plaintiffs’ cell phone and telephone records for the period from January 1, 2006, to the present including, but not limited to records of any text messages.
Response:
Request No. 11: The letter referenced in a posting by Plaintiff Harry R. Welty on www.lincolndemocrat.com on May 20, 2008, that outlined a possible case of bid rigging by Johnson Controls’ and all documents referencing or relating to that letter including but not limited to communications with the Minnesota State Attorney General’s office.
Response:
Request No. 12: 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.
Response:
Request No. 13: All Documents, Communications and Statement relating to, referring to, or evidencing the veracity of your allegation that JCI induced the School District to enter into an unlawful contract.
Response:
