Exhibit A

Case 6:22-cv-00049-H Document 158-1 Filed 01/31/24 Page 1 of 4 PageID 3180
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 

INTERROGATORIES TO PLAINTIFFS

Pursuant to Federal Rules of Civil Procedure 26 and 33, Defendants, by and through their 

undersigned counsel, hereby respectfully submit their first set of interrogatories. 

INSTRUCTIONS

For purposes of these interrogatories, the following definitions apply: 

1. When asked to answer an interrogatory, the request is for information within your 

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

information available to you, but also information 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. If you cannot fully and completely answer an interrogatory, please answer as much 

as you are able to, and provide the facts you rely upon in support of your contention that you cannot 

answer fully. To the extent an interrogatory is not answered because of an assertion of privilege, 

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

of particulars sufficient to enable the Court to assess its validity consistent with Federal Rule of 

Civil Procedure 26. If you object to answering only part of an interrogatory, please answer that 

part you do not object to answering and indicate what portion of the interrogatory to which your 

assertion of privilege extends.

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

attorney-client privilege. Please do not include any personally identifiable information of 

Plaintiffs.

4. If, in response to one or more of the interrogatories, you produce or identify any 

document(s) pursuant to Federal Rule of Civil Procedure 33(d), please identify the document(s) 

with specificity (for example, by BATES label).

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5. Please submit the answers to undersigned counsel at the email address below no 

later than thirty (30) days from date of service.

DEFINITIONS

For purposes of these interrogatories, the following definitions apply: 

1. “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.

2. “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.

3. “Case citation” shall mean the citation of the case as specified by the most recent 

edition of the Bluebook, including the case name and case number.

4. “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.

5. “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.

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

a litigation matter.

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

representation of a client in a litigation matter.

8. “Billing rate” shall mean the hourly rate that an Attorney charged to a client if 

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

alternative rate that an Attorney charged to a client if billed by an alternative rate.

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

10. “Each” means each and every.

11. 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.

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INTERROGATORIES

INTERROGATORY NO. 1: 

For each litigation matter handled on a non-pro bono basis, by any Attorney whose time 

forms the basis of the request for attorney’s fees in the above captioned litigation, please provide 

the case citation of any litigation matter on which the Attorney spent time since January 1, 2019,

and sought recompense, the billing rate charged by the Attorney for that litigation, the total amount 

charged by the Attorney for that litigation, and the total amount collected by the Attorney for that 

litigation.

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

Email: cassandra.m.snyder@usdoj.gov

Counsel for Defendants

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