IN THE UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF FLORIDA 

GAINESVILLE DIVISION

SHERRIE RUSSELL-BROWN, 

 Plaintiff, 

 CASE NO. 1:09-cv-00257-MP-AK 

v. 

 

THE UNIVERSITY OF FLORIDA, BOARD OF TRUSTEES, 

THE UNIVERSITY OF FLORIDA, LEVIN COLLEGE OF LAW, and 

ROBERT H. JERRY, II, in his individual and official capacities as 

Dean of the University of Florida, Levin College of Law, 

Defendants. 

___________________________________/ 

PLAINTIFF’S FIRST SET OF INTERROGATORIES, FIRST REQUESTS FOR THE 

PRODUCTION OF DOCUMENTS AND FIRST REQUESTS FOR ADMISSIONS 

PLEASE TAKE NOTICE THAT, pursuant to Rules 26, 33, 34 and 36 of the Federal 

Rules of Civil Procedure, Plaintiff hereby propounds the following Interrogatories to and 

Requests for Admissions from the Defendants to be answered fully, in writing and under oath, 

through a representative or agent who has knowledge of the facts, and in accordance with the 

Definitions and Instructions set forth below, within thirty (30) days after service thereof. Plaintiff 

also hereby requests that the Defendants produce the documents requested herein within thirty 

(30) days after service thereof, in accordance with the Definitions and Instructions set forth 

below. Copies of the requested documents shall be produced to the offices of Stevens, Hinds & 

White, PC, 116 West 111th Street, New York, New York 10026-4206, or at any other such place 

as may be agreed to by counsel. 

DEFINITIONS

A. The singular form of a word shall include the plural, and the plural shall include 

the singular. 

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B. The use of the present tense includes the past tense and vice versa. 

C. “All” shall be construed to include “any” and “each,” “any” shall be construed to 

include “all” and “each,” shall be construed to include “all” and “any,” in each case as is 

necessary to bring within the scope of these requests documents that might otherwise be 

construed as outside their scope. 

D. “And” and “or” shall be construed conjunctively or disjunctively, in each case as is 

necessary to bring within the scope of these requests documents that might otherwise be 

construed as outside their scope. 

E. The term “communication” means any occurrence whereby data, expressions, 

facts, opinions, advice, thought or other information of any kind is transmitted in any form, 

including without limitation any conversation, correspondence, discussion, e-mail, text, forum, 

negotiation, gathering, meeting, memorandum, message, note or posting or any other display on 

the Internet or World Wide Web. 

F. The terms “relate(s) to,” “related to” or “relating to” mean to refer to, being 

evidence of, memorialize, reflect, concern, pertain to or in any manner be connected with the 

matter discussed. 

G. “Complaint” refers to the complaint filed by the Plaintiff in this action, and any 

amendment(s) thereto. 

H. The term “concerning” means referring or relating to and includes without 

limitation analyzing, commenting on, comprising, connected with, constituting, containing, 

contradicting, discussing, describing, embodying, establishing, evidencing, memorializing, 

referencing, mentioning, pertaining to, recording, regarding, reflecting, responding to, setting 

forth, showing, or supporting, directly or indirectly. 

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I. The terms “correspondence” or “corresponding” refer to communications made 

between you and/or other person(s). 

J. The term “document” is used herein in the broadest sense permissible under Rule 

34 of the Federal Rules of Civil Procedure, and includes, but is not limited to, any written, 

recorded or tangible graphic matter, or any other means of preserving data, expression, facts, 

opinions, advice, thought, images, or other information of any kind, including without limitation 

all non-identical copies, drafts, out takes, subsequent versions, worksheets and proofs, however 

created or recorded, including without limitation audio tapes, annotations, calendars, 

correspondence, data or information of any kind recorded on compact discs, digital video 

diskettes, or any other type or form of diskettes for use with computers or other electronic 

devices, or any hard drive, diary entries, electronic recordings of any kind, e-mail, text, 

memoranda, notes, photographs, reports, telephone slips and logs, video cartridges and 

videotapes, and sites, databases, or other means of information storage or retrieval on the Internet 

or the World Wide Web. 

K. “Identify” means: 

(i) with respect to an individual, to identify the individual(s) by name, title, 

home and business address and phone and fax numbers, to specify the 

information the individual(s) has and to produce documents containing that 

person’s name, title, home and business address and phone and fax 

numbers; 

(ii) with respect to any entity other than a natural person, to identify its full 

name, present or last known address, form of organization (e.g., general 

partnership, corporation), state of incorporation or other organization, to 

produce documents containing its full name, present or last known address, 

form of organization (e.g., general partnership, corporation), state of 

incorporation or other organization, and to specify the information the 

entity has; 

(iii) with respect to a document, to identify the document by type, general 

subject matter, its date, its author(s), addressee(s) and recipient(s); 

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(iv) with respect to an event, to produce documents containing the date, 

location, and participants in those events. 

L. The term “including” means including without limitation. 

M. The term “person” means any natural person or “company limited by guarantee,” 

corporate, business, legal, academic, educational, professional, accrediting, investigatory, 

governmental, inter-governmental, non-governmental or non-profit body, agency, entity, 

institution, association, partnership or organization. References to any person or body, agency, 

entity, institution, association, partnership or organization shall include its officers, directors, 

employees, former employees, partners, agents, consultants, attorneys, legal representatives, 

adjudicators, investigators, solicitors, barristers, representatives, corporate parents, predecessors, 

successors, subsidiaries, and affiliates. 

N. The term “Academic Personnel” means your faculty members, and certain 

graduate and professional student appointments, and excludes members of your University 

Support Personnel System (USPS) and Technical, Executive, Administrative and Managerial 

Support (TEAMS). The “Academic Personnel” classification consists of positions having the 

principal responsibility of teaching and/or research, extension and/or providing administrative 

functions directly related to the academic mission and accomplishment of your goals. 

O. The term “grievance” means a dispute or complaint alleging a violation of your 

rules or regulations concerning tenure, promotion, non-renewal and termination of employment 

contracts, salary, work assignments, annual evaluation, lay-off and recall and other benefits or 

rights accruing to your faculty members pursuant to your rules or regulations. 

P. The terms “tenure probationary period” or “probationary period” mean that period 

of academic service in a tenure-accruing position at the University of Florida by the end of which 

the faculty member must be recommended for tenure or given notice of non-renewal. 

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Q. The term “instructional assignment” means the instruction of students who are 

registered for credit. 

R. “You” and “your” refers to the University of Florida, Board of Trustees, the 

University of Florida, Levin College of Law, Robert H. Jerry, II, in his individual and official 

capacities as Dean of the University of Florida, Levin College of Law, the named defendants in 

this action, their principals, trustees, directors, executives, officers, employees, former 

employees, predecessors, agents, consultants, attorneys, legal representatives, investigators, 

solicitors, barristers, any person acting or purporting to act on their behalf and other 

representatives. Unless otherwise specified, each Interrogatory, Request for Admission and 

Document Request is directed to all Defendants. 

S. “Plaintiff” means Sherrie Russell-Brown, the named plaintiff in this action, her 

principals, trustees, directors, executives, officers, employees, former employees, predecessors, 

agents, consultants, attorneys, legal representatives, investigators, solicitors, barristers, any 

person acting or purporting to act on her behalf and other representatives. 

T. “Relevant time period” means December 19, 2000 to December 31, 2007. 

INSTRUCTIONS

A. If any request herein for a document cannot be complied with in full, it shall be 

complied with to the extent possible, with an explanation as to why full compliance is not 

possible. 

B. The requests for documents herein are continuing in nature. If at any time 

documents are obtained in addition to those that have previously been produced to Plaintiff, 

prompt supplementation of such responses to these request is required. 

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C. These requests apply to all documents in your possession, custody or control, 

regardless of the location of such documents, and include documents within the possession, 

custody or control of your employees, agents or representatives, wherever located. 

D. Each document is to be produced (along with all drafts thereof) in its entirety, 

without abbreviation, expurgation, or redaction. In the event that a copy of a document, the 

production of which is requested, is not identical to any other copy thereof, by reason of any 

alterations, marginal notes, comments, or material contained therein or attached thereto, or 

otherwise, all such non-identical copies shall be produced separately. 

E. The documents requested herein shall be produced as they are kept in the usual 

course of business, or shall be organized and labeled to correspond to each document request 

herein. All documents that are physically attached to each other when located for production 

shall be left so attached. Documents that are segregated or separated from other documents, 

whether by use of binders, files, subfiles, or by dividers, tabs, or any other method, shall be left 

so segregated or separated. All labels or other forms of identification contained, placed, attached, 

or appended on or to any binders, files, subfiles, dividers, or tabs shall be produced. 

F. A request for documents shall be deemed to include a request for any or all 

transmittal sheets, cover letters, exhibits, enclosures, or attachments to the documents, in addition 

to the document itself, without abbreviation or expurgation. 

G. No request shall be read as limiting any other request. 

H. If, in responding to these requests, you claim any ambiguity in interpreting a 

request, or a definition or instruction applicable thereto, such claim shall not be utilized by you as 

a basis for refusing to respond, but instead you shall set forth as part of your response the 

language deemed to be ambiguous and the interpretation that you used in responding to the 

request. 

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I. If any document requested herein that was formerly in your possession, custody or 

control has been destroyed, discarded, or otherwise lost, the document shall be identified by 

stating: (a) the nature of the document, the number of pages (if applicable), its subject matter and 

its contents, including but not limited to any attachments or appendices; (b) the author or creator 

of the document and all persons to whom it was sent, including but not limited to cover copies or 

blind copies (if applicable); (c) the date on which the document was prepared or transmitted; (d) 

the date on which the document was lost, discarded, or destroyed; (e) the person who authorized 

and carried out the destruction; and (f) the name of any custodian of any existing copies of the 

document. 

J. In the event that any responsive material is maintained in electronic format, such 

material shall be produced in a reasonably usable and electronically searchable form, consistent 

with the requirements of Rule 34(b)(ii) of the Federal Rules of Civil Procedure. 

K. If any document responsive to these requests or any part thereof is withheld under 

a claim of attorney-client privilege, attorney work product immunity, or any other claim of 

privilege or immunity, provide a list of all such documents, identifying, with respect to each 

document: (a) the type of document; (b) the general subject matter of the document; (c) the date 

of creation of the document; (d) the author or creator of the document; (e) each recipient of the 

document; (f) the present custodian of the document; (g) the number of pages, attachments, and 

appendices in the document (if applicable); and (h) the specific privilege or immunity claimed. 

L. If no documents exist that are responsive to a particular paragraph of these 

requests, so state in writing. 

M. Each interrogatory shall be answered separately and fully in writing and under 

oath, unless it is objected to, in which event the reasons for the objection shall be stated with 

specificity. 

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N. You shall be under a continuing obligation to supplement your answers to the 

interrogatories set forth below to the extent provided in Rule 26(e)(1) of the Federal Rules of 

Civil Procedure. 

O. Each interrogatory calls not only for your knowledge, but also all information that 

is available to you by reasonable inquiry and due diligence, including inquiry of your employees, 

former employees, agents, representatives, attorneys and investigators. 

P. No interrogatory shall be read as limiting any other interrogatory. 

Q. If, in responding to these interrogatories, you claim any ambiguity in interpreting 

an interrogatory, or a definition or instruction applicable thereto, such claim shall not be utilized 

by you as a basis for refusing to respond, but instead you shall set forth as part of your response 

the language deemed to be ambiguous and the interpretation that you used in responding to the 

interrogatory. 

R. If you refuse to respond to any of these interrogatories or any portion of these 

interrogatories on the ground that it seeks information privileged against discovery, or 

information you deem to be neither relevant nor likely to lead to relevant evidence, or that you 

deem it otherwise improper as to either form or substance, you shall respond to so much of the 

interrogatories as you believe to be proper and shall state with specificity the basis for your 

objection or the privilege claimed. 

S. Each request for admission shall be answered separately and fully in writing and 

under oath. If you fail to respond or object to any request for admission within thirty (30) days 

after service of the Requests, the matter shall be deemed admitted under Rule 36 of the Federal 

Rules of Civil Procedure. As is more fully set out in Rule 36(a) of the Federal Rules of Civil 

Procedure, you must admit or deny each request for admission, and, where necessary, specify the 

parts of each request to which you object or cannot in good faith admit or deny. If you object to 

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only part of a request for admission, you must admit or deny the remainder of the request for 

admission. In the event that you object to or deny any request for admission or portion of a 

request for admission, you must state the reasons for your objection or denial. 

T. Each request for admission solicits all information obtainable by you from your 

employees, former employees, agents, representatives, attorneys and investigators. If you answer 

a request for admission on the basis that you lack sufficient information to respond, describe any 

and all efforts you made to inform yourself of the facts and circumstances necessary to answer or 

respond. If you cannot answer any request for admission in full after exercising due diligence to 

secure the full information to do so, so state and answer any request for admission to the extent 

possible, setting forth in detail the reasons why you cannot truthfully admit or deny the matter 

and detailing what you did in attempting to secure the unknown information. 

U. Your failure to admit any request for admission requires that you supplement your 

response to admit the matter if you, or any person acting your behalf, subsequently obtains 

additional information indicating that the matter should be admitted. The requests for admissions 

shall be deemed continuing and supplemental answers shall be required if you directly or 

indirectly obtain further information after your initial response, as provided by Rule 26(e) of the 

Federal Rules of Civil Procedure. 

INTERROGATORIES

1. Identify any and all persons with knowledge or information regarding 

correspondence concerning Plaintiff, from January 1, 2008 to the present. 

2. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning leaves of absence, including annual and FMLA leaves, for your 

faculty members. 

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3. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning requiring a fitness-for-duty certification from your faculty 

members, as a condition of their return from FMLA leave, and identify your faculty members 

who were required to submit a fitness-for-duty certification, as a condition of their return from 

FMLA leave, including, for each faculty member (a) the faculty member’s race, national origin 

and sex; (b) the faculty member’s academic rank, at the time of the request for FMLA leave and 

return from FMLA leave; (c) the dates of the faculty member’s FMLA leave and the pay status of 

the faculty member during their FMLA leave; (d) the date the faculty member submitted their 

fitness-for-duty certification and the date of the faculty member’s return from FMLA leave; (e) 

the faculty member’s college, department or unit; (f) whether the faculty member remains 

employed with you, and, if so, the faculty member’s current academic rank, college, department 

or unit; (g) if the faculty member is not still employed with you, the last date of employment and 

the name of the faculty member’s current employer; (h) whether the faculty member was a 

member of a collective bargaining unit, at the time of the request for FMLA leave. 

 4. Identify the persons who instructed defendant Jerry that Plaintiff was required to 

provide a fitness-for-duty certification. 

5. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning changes and notification of changes in your faculty member’s 

appointment(s), assigned duties and responsibilities, and state with specificity all changes and 

notification of changes in Plaintiff’s appointment(s), and assigned duties and responsibilities, 

after Plaintiff’s initial employment date, including, the reasons for the change, on August 21, 

2007, and the reasons why Plaintiff was not assigned or informed of her new duties and 

responsibilities, prior to September 13, 2007. 

 6. State the policies, procedures, and standards you have established, during the 

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relevant time period, concerning the “instructional assignments” of your faculty members, 

identify your faculty members who received “instructional assignments” for the fall 2007 

semester, after the fall 2007 semester began, and state with specificity Plaintiff’s September 13, 

2007 “instructional assignment,” including, the number and names of students registered for 

credit in Plaintiff’s course, the course number, the credits assigned to the course. 

 7. State the policies, procedures, and standards, during the relevant time period, 

concerning complaints of discrimination in your employment practices and state with specificity 

Plaintiff’s complaints of discrimination in your employment practices and any investigation(s) by 

you thereof. 

 8. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning complaints against your faculty members and state with 

specificity each complaint against Plaintiff, including, for each complaint: (a) whether the 

complaint was in writing or verbal; (b) whether the complaint was anonymous, and, if not 

anonymous, the name of the complainant; (c) whether the complaint was from outside or inside 

the University of Florida; (d) the date of the complaint; (e) the allegations in the complaint; (f) to 

whom the complaint was submitted; (g) who reviewed the complaint; (h) whether it was 

determined that the complaint had substance and that further action was necessary; (i) whether, 

and, if so, when Plaintiff submitted a written response to the complaint; (j) whether, and, if so, 

when the department chair or administrator submitted a report of their review of the complaint, 

together with Plaintiff’s written response, and the report’s conclusion; (k) any remedial and/or 

appropriate action(s) taken. 

 9. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning the termination, suspension, and/or disciplinary action(s) 

imposed on your faculty members and state with specificity the termination, suspension and/or 

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disciplinary action(s) imposed upon Plaintiff, including the reason(s) and details regarding 

notification. 

10. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning grievances and state with specificity the grievances filed by 

Plaintiff, including, for each grievance: (a) the date filed and with whom Plaintiff filed her 

grievance; (b) the allegations in Plaintiff’s grievance; (c) the step of the grievance process at 

which Plaintiff’s grievance was commenced and concluded; (d) who heard and/or reviewed 

Plaintiff’s grievance; (e) whether there was a meeting with Plaintiff regarding her grievance and, 

if so, the written and/or oral evidence presented at the meeting in support of Plaintiff’s grievance; 

(f) whether Plaintiff requested documents relevant to her grievance and whether Plaintiff was 

furnished with said documents; (g) whether and, if so, who, other than Plaintiff, was interviewed 

regarding Plaintiff’s grievance; (h) whether a report was submitted containing findings and 

recommendations with respect to Plaintiff’s grievance and, if so, the date of the report, by whom 

the report was submitted, the report’s findings and recommendations, and to whom the report was 

submitted; (i) whether a decision was rendered with respect to Plaintiff’s grievance and, if so, the 

date of the decision, by whom the decision was rendered, the detailed reasons for the decision, 

and to whom the decision was sent. 

11. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning the tenure and promotion of your faculty members. 

 12. State with specificity the contractual entitlements of your faculty members, during 

the relevant time period, including Plaintiff’s contractual entitlements. 

 13. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning notice and the end of the employment of your faculty members 

in a tenure-accruing position, holding the academic rank of associate professor, professor or 

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above, as defined in your rules or regulations, including 6C1-7.003(2), and identify those faculty 

members in a tenure-accruing position, holding the academic rank of associate professor, 

professor or above, as defined in your rules or regulations, including 6C1-7.003(2), whose 

employment with you ended prior to the beginning of the last year of their probationary period, 

including, for each faculty member: (a) race, national origin and sex; (b) college, department or 

unit; (c) whether the faculty member was a member of a collective bargaining unit; (d) the dates 

of the appointment period during which the faculty member’s employment ended; (e) the dates of 

the faculty member’s probationary period; (f) the date of the faculty member’s last day of 

employment; (g) whether the faculty member received notice concerning the end of their 

employment and, if so, whether notice was written or verbal; (h) how notice was sent to the 

faculty member; (i) whether the President of the University of Florida or a designee conferred 

informally with the faculty member concerning the end of their employment, before notice was 

sent; (j) the date and content of notice; (k) the compensation paid to the faculty member during 

the notice period, how compensation was paid and whether compensation was paid in a lump 

sum; (l) whether the faculty member entered into other full-time employment prior to the end of 

their last day of employment with you, and, if so, whether it was with or without the approval of 

the President of the University of Florida or designee; (m) whether the faculty member taught at 

the University of Florida during their notice period, and, if so, the dates of the faculty member’s 

notice period and the dates during which the faculty member taught. 

 14. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning the evaluation of your faculty members. 

 15. State with specificity the data in Plaintiff’s employment records upon which 

Plaintiff received her 9% merit raise, effective August 15, 2004. 

 16. Identify your faculty members who received merit raises beyond 1.2%, effective 

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the 2004-2005 academic year, including, for each faculty member: (a) race, national origin and 

sex; (b) the percentage of the raise; (c) academic rank of the faculty member during the 2004-

2005 academic year; (d) college, department or unit; (e) whether the faculty member remains 

employed with you, and, if so, the faculty member’s current academic rank, college, department 

or unit; (f) if the faculty member is not still employed with you, the last date of employment and 

the name of the faculty member’s current employer. 

 17. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning a mentoring program and mid-career review for your faculty 

members in their “tenure probationary period” and state with specificity the mentoring and midcareer review received by Plaintiff. 

 18. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning delegated authority, including contractual authority, over 

matters relating to your Academic Personnel and state with specificity the contracts, relating to 

your Academic Personnel, executed on your behalf, by your Senior Vice President for 

Administration. 

 19. State with specificity: (a) your funding sources; (b) the liability of the State of 

Florida for financial judgements against you; (c) the role, if any, of the State of Florida in your 

administration; (d) the extent, if any, of the co-mingling of your state and private funds; (e) the 

extent, if any, of the State of Florida’s dominion over your funding sources; (f) your autonomy 

from the State of Florida; (g) complaints filed against you under 42 U.S.C. §§ 1981 or 1983, 

during the relevant time period. 

 20. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning complaints of threats of violence and/or violence and state with 

specificity any investigation by you of Plaintiff’s complaints of threats of violence and/or 

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violence. 

 21. State the policies, procedures, and standards you have established, during the 

relevant time period, concerning the processing of faculty members’ payroll and state with 

specificity the processing of Plaintiff’s payroll, including: (a) payroll actions taken/changes 

made; (b) action date and effective date; (c) action(s) reason(s); (d) compensation frequency and 

compensation rate; (e) time and labor, time reporting and time reporting codes; (f) approvers and 

processors of Plaintiff’s payroll. 

REQUESTS FOR DOCUMENTS

 1. All correspondence concerning Plaintiff. 

2. All documents concerning Plaintiff. 

3. Each personnel manual, personnel handbook, faculty handbook, collective 

bargaining agreement, or other document defining the employment relationship of your faculty 

members, including your sick leave, vacation, and FMLA policies. 

 4. Each policy or manual concerning your equal employment opportunity policies. 

 5. All written complaints concerning defendant Jerry, and all documents concerning 

investigation of any oral or written complaint concerning defendant Jerry, including documents 

showing complaints of or investigations of allegations of discrimination in employment practices, 

including discrimination on the basis of race, creed, religion, color, marital status, protected 

veteran status, sex, national origin, disability, political opinions or affiliations, age, sexual 

orientation, sexual harassment, genetic information, or handicap. 

6. All documents maintained for the purposes of any disciplinary proceeding brought 

against or any investigation of misconduct by defendant Jerry. 

 7. All documents constituting employment records maintained by you concerning 

defendant Jerry. 

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8. All documents constituting employment records maintained by you concerning 

Plaintiff. 

9. All documents used to answer any Interrogatory or Request for Admission 

propounded by Plaintiff including, but not limited to, Plaintiff’s First Set of Interrogatories and 

First Requests for Admissions. 

REQUESTS FOR ADMISSIONS

1. Admit that, in an e-mail dated August 25, 2007 3:49 pm, Plaintiff told you that she 

would be contacting the EEOC’s Miami office. 

2. Admit that, on August 20, 2007, defendant Jerry received a voice mail message 

and e-mails dated August 20, 2007, 12:08 pm, 2:39 pm and 3:31 pm, from Plaintiff. 

3. Admit that, according to your rules and regulations, including 6C1-7.048(4) and 

6C1-7.042(2)(c), counseling shall not be and is not considered disciplinary action. 

4. Admit that Dejawdya Butler complained to you about white male students in her 

class shuffling their feet on the floor whenever African-American students would rise to speak. 

5. Admit that, according to your rules and regulations, including 6C1-7.019(7), all 

discussions of evaluations of employee performance compiled for promotion and/or tenure shall 

be considered confidential. 

6. Admit that, during the 2007-2008 academic year, Plaintiff held a continuing fulltime tenure-accruing appointment at the academic rank and title of Associate Professor. 

 7. Admit that you had knowledge that one of Plaintiff’s students, Thomas J. Obhof, 

acted aggressively towards Plaintiff, that then Associate Dean George Dawson communicated 

with Mr. Obhof about his actions towards Plaintiff and that Associate Dean Christine Klein 

communicated with Plaintiff about Mr. Obhof’s actions towards her. 

8. Admit that, as Senior Vice President for Administration, Kyle Cavanaugh did not 

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have the authority to execute, on your behalf, contracts relating to Academic Personnel. 

9. Admit that you had knowledge of Plaintiff’s financial circumstances, as a result of 

her leave without pay status, beginning August 30, 2007. 

Dated: April 12, 2010 Stevens, Hinds & White, PC 

 

_________________ 

Lennox S. Hinds 

New York Bar No. 8196 

116 West 111th Street 

New York, NY 10026-4206 

(212) 864-4445 

(212) 222-2680 (fax) 

lawfirmshw@yahoo.com 

Attorney for Plaintiff 

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