Exhibit B

Case 6:22-cv-00049-H Document 158-2 Filed 01/31/24 Page 1 of 5 PageID 3184
UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS

SAN ANGELO DIVISION

LUKE T. CHRISMAN,

Plaintiff,

v.

LLOYD J. AUSTIN, III,

United States Secretary of Defense, et al.,

Defendants.

No. 6:22-cv-0049-H

DEFENDANTS’ FIRST SET OF 

REQUESTS FOR PRODUCTION TO PLAINTIFFS

Pursuant to Federal Rules of Civil Procedure 26 and 34, Defendants, by and through their 

undersigned counsel, hereby respectfully submit their first set of requests for production. 

INSTRUCTIONS

For purposes of these interrogatories, the following definitions apply: 

1. When asked to produce a document, the request is for information within your 

actual or constructive possession, custody or control. Your answers must therefore include not 

only information available to you, but also that is available to your attorneys, associates, 

employees, representatives, agents, and all other persons acting under, by, or through you, or 

subject to your control or supervision, or acting on your behalf. 

2. To the extent a document is not produced because of an assertion of privilege, 

please state the specific privilege relied upon and support the claim of privilege with sufficient 

information to enable Defendants and the Court to assess the validity of that assertion consistent 

with Federal Rule of Civil Procedure 26. If you object to producing only part of a requested 

document, please produce that portion of the document you do not object to producing and indicate 

what portion you have withheld based on an assertion of privilege.

3. These requests do not seek information the revelation of which would violate the 

attorney-client privilege. Please redact any personally identifiable information of Plaintiffs.

4. Unless specified otherwise in a specific request the time period for these requests 

is January 1, 2019 to present.

5. Please provide the requested documents to undersigned counsel no later than thirty 

(30) days from date of service or at another reasonable time specified in the response.

Case 6:22-cv-00049-H Document 158-2 Filed 01/31/24 Page 2 of 5 PageID 3185
2

DEFINITIONS

For purposes of these interrogatories, the following definitions apply: 

1. “Document” means the original and any draft or copy of any written, recorded or 

graphic materials of any type and in any form (including those maintained in electronic form, 

including on any social media accounts) in your possession, custody, knowledge, or control,

including your attorneys, agents, and representatives. 

2. “Interrogatory” or “interrogatories” refers to Defendants’ interrogatories to 

Plaintiffs in the above-captioned case, including those served concurrently with any requests for 

production.

3. “Firms” includes any and all law firms retained to represent Plaintiffs in this 

lawsuit, including Siri & Glimstad LLP, Christ Wiest Law PLLC, Bruns, Connell, Vollmar & 

Armstrong LLC, and S&L Law PLLC.

4. “Plaintiffs” shall mean Robert Schelske, Huntley W. Bakich, Zakai Bukfin, 

Samuel L. Conklin, Joshua J. Costroff, Samuel Galloway, Dominic O. Mell, Collin M. Morrison, 

Nicholas Saballa, Peter Testa, and Luke T. Chrisman.

5. “Litigation matter” shall mean any case brought before a court, board, 

commission, or tribunal in any federal, state, or international jurisdiction, including but not limited 

to any military board of corrections or any court, board, commission, or tribunal governed by the 

Uniform Code of Military Justice.

6. “Attorney” shall mean any individual who is employed in the practice of law and

is licensed to practice law in any state, and who submitted a request for fees in the above-captioned 

case.

7. “Time” shall mean any amount of hours or increments of hours spent working on 

a litigation matter.

8. “Recompense” shall mean any monetary charges arising out of an Attorney’s 

representation of a client in a litigation matter.

9. “Billing rate” shall mean the hourly rate that a Firm or an Attorney charged to a 

client if billed by the hour; or the flat rate that a Firm or an Attorney charged to a client if billed 

by a flat fee; or the alternative rate that a Firm or an Attorney charged to a client if billed by an 

alternative rate.

10. “And” and “or” shall be construed conjunctively and disjunctively.

11. “Each” means each and every.

Case 6:22-cv-00049-H Document 158-2 Filed 01/31/24 Page 3 of 5 PageID 3186
3

12. The singular form of any word shall also be construed as the plural, and vice versa. 

Verbs shall be construed as though they were in the past tense, the present and the future tense, 

and vice versa. In general, the interrogatories should be construed as broadly as possible.

REQUESTS FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 1: 

Please produce all documents identified in response to Defendants’ interrogatories in this 

action.

REQUEST FOR PRODUCTION NO. 2: 

Please produce all retainer agreements executed with a client regarding representation in 

any case identified in Interrogatory No. 1.

REQUEST FOR PRODUCTION NO. 3: 

Please produce all retainer agreements executed with Plaintiffs regarding representation in 

the above-captioned case.

Dated: January 26, 2024 Respectfully submitted,

BRIAN M. BOYNTON

Principal Deputy Assistant Attorney General 

ALEXANDER K. HAAS

Branch Director

JOSHUA E. GARDNER

Special Counsel

/s/ Cassandra M. Snyder

ANDREW E. CARMICHEAL

Senior Trial Counsel

KERI BERMAN

CASSANDRA M. SNYDER

Trial Attorneys

United States Department of Justice

Civil Division, Federal Programs Branch

1100 L Street NW, Rm. 11204

Washington, D.C. 20530

Tel.: (202) 415-7729 / Fax: (202) 305-7538

Case 6:22-cv-00049-H Document 158-2 Filed 01/31/24 Page 4 of 5 PageID 3187
4

Email: cassandra.m.snyder@usdoj.gov

Counsel for Defendants

Case 6:22-cv-00049-H Document 158-2 Filed 01/31/24 Page 5 of 5 PageID 3188