Exhibit 1

Case: 1:20-cv-03535 Document #: 56-1 Filed: 02/25/22 Page 1 of 7 PageID #:313
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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

STATE OF ILLINOIS, )

)

Plaintiff, )

) Case No. 1:20-cv-03535

v. )

)

CSL PLASMA, INC. and CSL BEHRING, ) The Honorable Mary Rowland

LLC, )

)

Defendants. )

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANTS

Plaintiff State of Illinois (the “State”), by its attorney, Kwame Raoul, Attorney General of 

Illinois, pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, hereby requests that 

Defendants CSL Plasma, Inc. and CSL Behring, LLC respond to the following interrogatories in 

writing and under oath:

DEFINITIONS AND INSTRUCTIONS

For the purposes of these Interrogatories, the following definitions and instructions shall 

apply:

1. “Defendants” refers to all named defendants. If a response to an interrogatory 

only applies to one of the defendants, or if there are different answers for each defendant, the 

answer shall identify which answer applies to which defendant.

2. “You,” “your,” and “CSL” shall refer to the named Defendants in this litigation, 

including all employees, volunteers, board members, agents, advisory board members, and any 

other person who provides services in connection with your operation or practice.

3. “Document(s)” or “communication(s),” unless otherwise specified, means all 

writings and electronic writings of any kind, including the originals and all non-identical copies 

whether different from the originals by reason of any notations made on such copies or 

otherwise, including without limitation, emails, correspondence, memoranda, notes, diaries, 

statistics, letters, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, 

returns, summaries, pamphlets, books, inter-office and intra-office communications, internet 

communications, notations of any sort of conversations, telephone calls, meetings or other 

communications, bulletins, printed matter, computer printouts, teletypes, telefax, invoices, work 

sheets, as well as all drafts, alterations, modifications, changes and amendments of any of the 

foregoing, and graphic or oral records or representations of any kind (including, without 

limitation, photographs, charts, graphs, microfiche, microfilm, videotapes, recordings, motion 

pictures), and any electronic mechanical or electric records or representations of any kind 

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(including, without limitation, tapes, cassettes, discs, recordings, CDs and computer memories). 

Documents refer to those which are or have previously been in your possession (whether actual 

or constructive), custody or control (whether immediate or extended), or of which you have 

knowledge.

4. “Document” shall also refer to any other data compilations from which 

information can be retrieved or obtained, and translated, if necessary, by you and through 

computers or detection into reasonably usable form.

5. “Person” means any natural person, corporation, partnership, proprietorship, 

association, governmental entity, agency, group, organization, or group of persons.

6. Singular terms shall be deemed to include the plural, and plural terms shall be 

deemed to include the singular.

7. “Identify” with respect to any “document” the following information regardless of 

whether the document is deemed privileged or subject to any claim of privilege:

(a) the title or other means of identification of each such document;

(b) the date of each such document;

(c) the author or preparer of each such document, including the name, 

address, telephone number and employer of the author or preparer;

(d) a summary of the contents of each such document;

(e) the name, address and telephone number of the person or persons who 

have custody or control of the original of each such document;

(f) the name, address and telephone number of any and all persons who have 

custody or control over copies of such documents; and

(g) any claims of privilege claimed and the grounds supporting the purported 

claim of privilege.

In lieu of providing a full description of the document in accordance with this paragraph, 

you may attach a copy of the document for which a description is requested, and in your answer 

to the interrogatory only provide those items of description requested which do not appear on the 

face of the document.

8. “Identify” with respect to any person the person’s name, address, telephone 

number, and employer.

9. If any interrogatory herein cannot be answered in full after exercising due 

diligence to secure the information to do so, it shall be answered to the extent possible with an 

explanation as to the reasons for your inability to answer the remainder and stating whatever 

information, knowledge or belief you do have concerning the unanswered portion, along with the 

basis for such information, knowledge and belief.

10. To the extent that you believe that an interrogatory is objectionable, answer so 

much of the interrogatory as, in your view, is not objectionable and separately state the portion of 

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each interrogatory to which you object and the grounds for your objection.

11. To the extent that you believe that an interrogatory calls for information subject to 

a privilege, answer so much of each interrogatory that, in your view, is not privileged, and for the 

remainder, state the nature and basis of the claim of privilege.

12. These interrogatories are continuing in nature and must be supplemented 

promptly if you obtain additional or different information related to any response at any time 

before the termination of this action.

13. If you cannot answer an interrogatory because of privacy concerns, please 

indicate as such in your response so the parties can meet and confer about the entry of an 

appropriate protective order.

INTERROGATORIES

1. Identify all persons with discoverable information regarding the allegations, 

claims, and responses in the pleadings (the complaint, answer, and affirmative defenses) and 

identify the subjects of that information.

2. Provide the names, addresses, and telephone numbers of the owners and operators 

of CSL Plasma, including but not limited to partnerships, corporations, parent corporations, 

shareholders, subsidiaries, franchisors, franchisees, management companies, and any other 

individuals or entities that own or operate CSL Plasma.

3. List all facilities that you own or operate in the State of Illinois, stating their name 

and legal address.

4. Identify any and all individuals responsible for ensuring that Defendants comply

with federal and state disability and civil rights laws. 

5. Describe in detail Defendants’ policies and practices related to providing

reasonable accommodation or reasonable modifications of your standard donor intake and 

plasma donation procedures for disabled individuals, including providing effective 

communication (requests for sign language interpreters, braille, real time captioning, etc.), to any 

donor or potential donor, including but not limited to responding to requests for effective 

communication, types of effective communication provided, any auxiliary aids available by 

location, and any training on effective communication given to staff.

6. Identify all risk factors, or any factors that result in a deferral or denial of any 

type, or any factor that raises a “flag” or causes or requires a potential donor to provide followup information or documentation or further investigation by an employee or other agent of 

Defendants into the eligibility of a potential or repeat donor. For each such factor, describe in 

detail Defendants’ policies or practices for suggested or required responses to the identification 

of that factor (e.g., rejection of a potential donor) and the factual, evidentiary, scientific, medical, 

economic, or other basis, if any, relied upon by Defendants for the policies or policies 

referenced.

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7. Describe each method used by Defendants to screen and/or track potential donors 

and repeat donors (i.e., electronic portal, paper form, database system, etc.), including individuals 

who attempted to donate but were rejected or deferred, and the collection method or methods each 

location uses. For locations where more than one method is used, please provide the percentage of 

use for each collection method.

8. Describe in detail the process of giving plasma from initial screening to collection, 

including any scheduling of collection, repeat collection and screening process, compensation, 

terms of compensation, method of compensation, options for redemption of compensation, rewards 

programs used by Defendants, and how those rewards programs function.

9. Describe in detail any anti-discrimination training taken by or given to Defendants’

employees, including the anti-discrimination topics covered and dates of completion for each

employee.

10. Identify all complaints formal or informal, written or verbal, you have received 

regarding to the denial or deferral of donors or potential donors, where the complainant alleges the 

basis of denial or deferral was their disability.

11. Identify and describe the system Defendants use to track and/or resolve any 

complaints that Defendants receive from any donors, potential donors, employees, or other 

members of the public with regards to Defendants’ business practices, including but not limited 

to plasma donation and collection.

12. Identify any donor or potential donors who have been permanently or temporarily 

deferred and state the reason for deferral.

13. Identify all persons who assisted in answering these interrogatories or located, 

authored, and approved the documents produced in the request for production. 

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Dated: December 4, 2020 Respectfully submitted,

KWAME RAOUL

Attorney General of Illinois

/s/ Elizabeth Morris___________________

Elizabeth Morris

(emorris@atg.state.il.us)

Neil Kelley

(nkelley@atg.state.il.us)

Office of the Illinois Attorney General

100 West Randolph Street, 11th Floor

Chicago, Illinois 60601

Ph. (312) 814-3000

Counsel for Plaintiff State of Illinois

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CERTIFICATE OF SERVICE

I, Elizabeth Morris, an attorney, certify that on December 4, 2020, I served the 

undersigned attorneys with Plaintiffs’ First Set of Interrogatories to Defendants via electronic 

mail:

Eric A. Berg

(eric.berg@ogletree.com)

Jennifer Colvin

(jennifer.colvin@ogletreedeakins.com)

OGLETREE, DEAKINS, NASH, SMOAK

 & STEWART P.C.

155 North Wacker Drive, Suite 4300

Chicago, Illinois 60606

Counsel for Defendants

/s/ Elizabeth Morris

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