DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTIFF’S

FIRST SET OF INTERROGATORIES TO DEFENDANT – Page 1

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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

KRISHNENDU DASGUPTA,

Plaintiff,

v.

BECKETT COLLECTIBLES, LLC

Defendant.

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CIVIL ACTION NO. 4:23-CV-00838

JUDGE MAZZANT

DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTIFF’S

FIRST SET OF INTERROGATORIES

To: KRISHNENDU DASGUPTA, c/o their counsel of record, W.D. Masterson, Kilgore 

& Kilgore, PLLC, 3141 Hood Street, Suite 500, Dallas, Texas 75219.

Pursuant to Federal Rules of Civil Procedure 26 and 33, Defendant Beckett Collectibles, 

LLC (“Beckett” or “Defendant”), hereby serves this, its Objections and Responses to Plaintiff 

Krishnendu Dasgupta (“Plaintiff” or “Dasgupta”) First Set of Interrogatories as follows:

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Dated: April 17, 2024 Respectfully submitted, 

CONDON TOBIN SLADEK THORNTON

NERENBERG, PLLC

/s/ Abigail R.S. Campbell__________ 

Aaron Z. Tobin 

Texas Bar No. 24028045 

atobin@condontobin.com

Abigail R.S. Campbell 

Texas Bar No. 24098959 

acampbell@condontobin.com 

8080 Park Lane, Suite 700 

Dallas, Texas 75231 

Telephone 214-265-3800 

Facsimile 214-691-6311 

 ATTORNEYS FOR DEFENDANT

CERTIFICATE OF SERVICE

I certify that on April 17, 2024 the foregoing document was served on the following via 

e-mail, pursuant to the Federal Rules of Civil Procedure.

W.D. Masterson

KILGORE & KILGORE, PLLC

3141 Hood Street, Suite 500 

Dallas, Texas 75219 

Telephone: (214) 969-9099 

Facsimile: (214) 953-0133 

wdm@kilgorelaw.com

Attorneys for Plaintiff

/s/ Abigail R.S. Campbell 

Abigail R.S. Campbell 

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STATEMENT REGARDING OBJECTIONS AND RESPONSES

1. Unless otherwise indicated, Defendant does not interpret the form of the 

individual requests to seek information regarding or relating to: (1) correspondence between 

Defendant and its attorneys; (2) communications between or among Defendant and their 

representatives subsequent to notification that Plaintiff would be asserting a claim made in 

connection with the investigation and defense of such claim; (3) notes or other work product of 

Defendant’s attorneys; (4) other documents created by or for lawyers or their representatives 

(including investigators); and (5) documents prepared by consulting experts, regardless of 

whether the documents apply to this or another suit or claim which has been made or is 

anticipated. If any of the specific requests are intended by Plaintiff to include any of these 

privileged items, Defendant requests that Plaintiff identify in writing the requests, and the 

specific privileged information that is sought. 

2. Defendant objects to Plaintiff’s Additional Instructions No. 4 as overbroad and 

unduly burdensome because it seeks to require Defendant to search for and detail information 

beyond what is required by the Federal Rules of Civil Procedure. 

3. Defendant objects to Plaintiff’s time period, January 1, 2019 to the present, as 

overbroad and unduly burdensome because it includes a significant time period that is not 

relevant to the claims and defenses at stake in this litigation and the burden on Defendant to 

search for and produce such information is outweighed by any benefit to Plaintiff, if any. 

Specifically, the Employment Agreement between Plaintiff and Defendant is dated March 24, 

2022 and was not effective until September 2022. Plaintiffs causes of actions are solely based on 

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his employment with Defendant. Consequently, including over three years’ time prior to even 

executing the employment agreement is unreasonable. 

4. Defendant objects to Plaintiff’s definition of “incident” as vague and ambiguous 

because there are no facts or circumstances concerning the payment of commissions to Plaintiff 

described in the Petition. 

OBJECTIONS AND RESPONSES TO FIRST SET OF INTERROGATORIES

INTERROGATORY NO. 1: Identify the person or persons answering these 

Interrogatories or who contributed information used in answering these Interrogatories. If more 

than one person provided the answers or information, identify the specific Interrogatories 

answered by each person. 

ANSWER: In response to this interrogatory, Beckett states that Kevin Isaacson, with the 

assistance of counsel, contributed information used in answering these interrogatories. 

INTERROGATORY NO. 2: Identify each and every allegation in Plaintiff’s Original 

Complaint filed in this lawsuit which you assert is false or inaccurate, and detail specifically all 

facts, proof, or evidence you claim prove these allegations are false or inaccurate, and identify 

the true or accurate facts which demonstrate the falsity or inaccuracy of such allegations. 

ANSWER: Beckett objects to this interrogatory because the phrase “Original 

Complaint” is not defined by Plaintiff and is vague and confusing as Plaintiff has not filed a 

Complaint in this matter. Beckett further objects to this request as premature as such information 

will be provided if and when Beckett is required to file an answer to Plaintiff’s Petition. 

INTERROGATORY NO. 3: Please provide all reasons Defendant terminated Plaintiff.

ANSWER: In response to this interrogatory, Beckett states that as Plaintiff has 

previously been informed, Beckett terminated Plaintiff for Cause as a result of his 

insubordination and dishonesty in project updates that caused material injuries to Beckett. 

INTERROGATORY NO. 4: Identify every lawsuit filed in the last 3 years to the 

present against you or your predecessor or successor corporations alleging any cause of action 

regarding breaches of contract, or any unfair labor or employment practices. 

ANSWER: Beckett objects to this interrogatory as unduly burdensome, overbroad, and 

not likely to lead to the discovery of admissible evidence because it seeks unrelated lawsuit 

information for a period of three years that in no way relate to the litigation filed by Plaintiff, 

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which does not allege any unfair labor or employment practices and only relates to Plaintiff’s 

Employment Agreement. Additionally, such information, if any, is publicly available and thus, 

obtainable through less burdensome means than from Beckett. 

INTERROGATORY NO. 5: Identify every person Defendant interviewed, spoke with, 

talked to, and/or consulted about the facts giving rise to Plaintiff’s termination, and for each such 

person, provide his or her full name job title, and if not still employed by Defendant, his or her 

last known home address and telephone number. 

ANSWER: In response to this interrogatory, Beckett refers Plaintiff to its Initial 

Disclosures. As an update to Beckett’s Initial Disclosures, Scott Roskind and Joseph Smith are 

no longer employed at Beckett. 

INTERROGATORY NO. 6: Set forth what actions Defendant took after Plaintiff 

complained about Justin Richmond. 

ANSWER: Beckett objects to this interrogatory as unduly burdensome, overbroad, and 

not likely to lead to the discovery of admissible evidence because it seeks unrelated lawsuit 

information for a period of three years that in no way relate to the litigation filed by Plaintiff. 

Thus, the burden on Beckett to search for and produce such information is outweighed by any 

benefit to Plaintiff, if any. 

INTERROGATORY NO. 7: Set forth the names of the individuals who were 

interviewed about Plaintiff’s about Justin Richmond [sic]. 

ANSWER: Beckett objects to this interrogatory as unduly burdensome, overbroad, and 

not likely to lead to the discovery of admissible evidence because it seeks unrelated lawsuit 

information for a period of three years that in no way relate to the litigation filed by Plaintiff. 

Thus, the burden on Beckett to search for and produce such information is outweighed by any 

benefit to Plaintiff, if any.

INTERROGATORY NO. 8: Set forth every reason why you did not provide Plaintiff 

the separation agreement when terminated.

ANSWER: In response to this interrogatory, Beckett states that it terminated Plaintiff 

for Cause, which pursuant to the Employment Agreement, does not require the execution of a 

separation agreement.

 

INTERROGATORY NO. 8: Set forth every reason why you did not pay Plaintiff the 

severance payment equal to his current base salary when terminated.

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ANSWER: In response to this interrogatory, Beckett states that it terminated Plaintiff 

for Cause, which pursuant to the Employment Agreement, does not entitle Plaintiff to a 

severance payment.

INTERROGATORY NO. 9: Please explain in detail why the interviews were conducted 

in the conference room next to David Holloways office. 

ANSWER: Beckett objects to this request as vague and ambiguous in total and does not 

allow Beckett to determine what information is responsive. Specifically, Beckett is not aware 

what “interviews” Plaintiff is referencing and why or how such interviews are relevant to this 

litigation.

INTERROGATORY NO. 10: Please provide a list of witnesses and what you believe 

they will testify to at trial, including role at the time of the termination and current role at 

Beckett.

ANSWER: Beckett objects to this request as premature. Beckett will provide a witness 

list at the appropriate time as required by the Federal Rules and the Court’s Scheduling Order. 

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VERIF'ICATION

STATE OF TEXAS

COUNTY OF DALLAS

BEFORE ME, the undersigned authority, on this day personally appeared Kevin

Isaacson, known to me to be the person whose name is subscribed to the foregoing instrument,

and acknowledged to me to be the duly authorized representative of Beckett Cotleitibles , LLC,

Defendant in the above-numbered and entitled cause of action, and after being duly swom, stated

that the above and foregoing factual statements contained in the intenogatories are true and

correct.

Kevin Isaacson, CEO

Beckett Collectibles, LLC

AND SUBSCRIBED BEFORE ME by the said AD on this the

2024to certify which witness my hand and

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CYNTHIA D NAVARRO

Notary lD #10012167

My Commisslon Explres

Decamber 7, 2026

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