***REDACTED – Pursuant to Local Rule 26.2***

Exhibit 5

Case: 1:20-cv-03535 Document #: 56-5 Filed: 02/25/22 Page 1 of 12 PageID #:341
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. ) 

 

DEFENDANT CSL PLASMA INC.’S 

ANSWERS TO PLAINTIFF FIRST SET OF INTERROGATORIES 

For its Answers to Plaintiff’s First Set of Interrogatories, Defendant CSL Plasma Inc. 

(“Defendant” or “CSL”), hereby responds and, through its counsel, objects to the Interrogatories 

served by Plaintiff State of Illinois (“Plaintiff” or “State”). All responses are made without in any 

way waiving or intending to waive, but on the contrary, intending to preserve and preserving: 

1. All objections as to competency, relevance, materiality, privilege, and 

admissibility of evidence for any purpose in any subsequent proceeding or trial of this or any 

other action. 

2. The right to object to the use of any of these responses, or the documents 

identified and/or produced, in any subsequent proceeding or the trial of this or any other action 

on any ground; 

3. The right to object on any ground at any time to a demand for further response to 

these or any other discovery proceedings involving or relating to the subject matter of the 

interrogatories; and 

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4. The right to supplement and/or amend these responses based upon the discovery 

of additional documents and/or information. 

GENERAL OBJECTIONS 

Defendant objects generally to each of the interrogatories by Plaintiff to the extent that: 

1. The burden or expense of complying with the interrogatories outweigh their likely 

benefits considering the needs of the case, the amount in controversy, the parties’ resources, the 

importance of the issues at stake in the action, and the importance of the discovery in resolving 

the issues; 

2. The interrogatories are overly broad and any attempt by Defendant to respond 

would be unduly burdensome, expensive, harassing, and oppressive; 

3. The interrogatories seek information that is protected by the attorney-client 

privilege or the work product doctrine, or which is otherwise protected against or privileged from 

disclosure by law or rule of court; 

4. The interrogatories seek information protected against or privileged from 

disclosure as to the mental impressions, conclusions, opinions, or legal theories of an attorney or 

other representative of Defendant; 

5. The interrogatories seek information that is not within the knowledge, possession, 

or control of Defendant or from any other person who is not a party to this action; 

6. The interrogatories are so vague and ambiguous that they do not properly advise 

Defendant as to the information requested, thereby requiring Defendant to guess or speculate as 

to the information Plaintiff seeks; 

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7. The interrogatories request information and/or documents that Plaintiff already 

possesses or to which it has equal access; 

8. The interrogatories are overly broad as to the location and geographic area of 

inquiry; 

9. The interrogatories seek information for an unreasonable, irrelevant, or 

unspecified period of time; 

10. The interrogatories seek information improperly premised upon assumptions 

and/or allegations; 

11. The interrogatories seek business information which is of a confidential, trade 

secret, and/or proprietary nature; 

12. The interrogatories seek to impose upon Defendant any obligation, including the 

obligation to provide supplemental responses, in excess of that required by the Federal Rules of 

Civil Procedure; 

13. The interrogatories purport to impose obligations not contained in the Federal 

Rules of Civil Procedure relating to discovery generally or interrogatories specifically; 

14. The interrogatories define a term rendering the interrogatories overbroad, unduly 

burdensome, harassing, or purport to require an unreasonable investigation; 

15. If any information or documents within the scope of the attorney-client or the 

attorney work product doctrine are inadvertently disclosed by these answers, Defendant has not 

done so intentionally. Defendant reserves the right to assert the privileges at any time in these 

proceedings, and further reserves its right to request return of all privileged information and 

documents, including any copies of abstracts of such information or documents. In addition, all 

evidentiary objections are preserved and no waiver of any objections shall be implied from these 

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answers. To the extent that these answers might arguably waive an otherwise assertable 

objection or claim of privilege, such waiver shall be limited to these answers only and shall not 

extend to any further discovery requests; 

16. All of Defendant’s general objections shall be deemed continuing throughout the 

responses to the specific interrogatories that follow, even when not further referred to in said 

responses; and 

17. Defendant will make reasonable efforts to respond to each interrogatory, to the 

extent that no objection is made, as Defendant understands and interprets the interrogatory. If 

Plaintiff subsequently asserts any interpretation of any interrogatory that differs from 

Defendant’s interpretation, Defendant reserves the right to supplement its objections and 

responses. 

ANSWERS 

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. 

ANSWER: 

Donor M.P. (name and information withheld) 

Defendant believes that Donor M.P. is the individual referred to in Plaintiff’s complaint, 

allegedly deferred on November 16, 2018. Donor M.P. possesses information relating to her 

alleged disability and need for a service animal, the facts relating to her visit to CSL Plasma’s 

Rockford, Illinois facility, and Plaintiff’s alleged damages in the present action. 

Kristi Davis, current CSL Plasma Center Manager, Rockford facility 

c/o Ogletree, Deakins, Nash, Smoak & Stewart, P.C. 

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 Ms. Davis possesses information regarding CSL Plasma’s policies and procedures, the 

history of Donor M.P. and Donor M.P.’s alleged deferral on November 16, 2018, and facts that 

may relate to Plaintiff’s claims in the present action. 

Dawn Leamon, Medical Staff Associate, Rockford, IL plasma collection center 

c/o Ogletree, Deakins, Nash, Smoak & Stewart, P.C. 

Ms. Leamon possesses information regarding CSL Plasma’s policies and procedures, the 

history of Donor M.P. and their alleged deferral on November 16, 2018, and facts that may relate 

to Plaintiff’s claims in the present action. 

c/o Equip for Equality 

 

 possesses information relating to 

, the facts relating to his claims, and Plaintiff’s alleged 

damages in the present action. 

Justin Gronbach, CSL Plasma Center Manager, Montgomery, IL plasma collection center 

c/o Ogletree, Deakins, Nash, Smoak & Stewart, P.C.* 

 As current center manager, Mr. Gronbach may possess information regarding CSL 

Plasma’s policies and procedures, donation history and deferral on July 28 and 30, 

2018, and facts that may relate to Plaintiff’s claims in the present action. 

Dmitriy Gubarev, Montgomery, IL plasma collection center 

c/o Ogletree, Deakins, Nash, Smoak & Stewart, P.C.* 

Mr. Gubarev has information regarding CSL Plasma’s policies and procedures, 

 donor history and deferral on July 28 and 30, 2018, and facts that may relate to 

Plaintiff’s claims in the present action. 

Bridjet Norman, Montgomery, IL plasma collection center 

c/o Ogletree, Deakins, Nash, Smoak & Stewart, P.C.* 

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Ms. Norman has information regarding CSL Plasma’s policies and procedures, 

 donor history and deferral on July 28 and 30, 2018, and facts that may relate to 

Plaintiff’s claims in the present action. 

*These persons may be contacted only through the undersigned counsel. 

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. 

ANSWER: Defendant objects to this interrogatory as it is overly broad and unduly burdensome. 

Defendant further objects to this interrogatory as it vague and ambiguous and seeks information 

that is irrelevant to this action and not reasonably calculated to lead to the discovery of 

admissible evidence. Without waiving this objection, Defendant states that it is a subsidiary of 

co-defendant CSL Behring L.L.C., which has been improperly named as a defendant in this case.

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

and legal address. 

ANSWER: This interrogatory requests information to which Plaintiff has equal access:

https://www.cslplasma.com/find-a-donation-center 

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

with federal and state disability and civil rights laws. 

ANSWER: Defendant objects to this interrogatory as it is overly broad and unduly burdensome. 

Defendant further objects to this interrogatory as it vague and ambiguous and seeks information 

that is irrelevant to this action and not reasonably calculated to lead to the discovery of 

admissible evidence. Without waiving its objections, Defendant further states that it is not a 

public accommodation subject to federal and state accessibility statutes, and thus it is not 

obligated to comply with accessibility laws as they may relate to donors or other invitees. 

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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. 

ANSWER: Defendant objects to this interrogatory as it is overly broad and unduly burdensome. 

Defendant further states that it is not a public accommodation subject to federal and state 

accessibility statutes and is thus not obligated to provide reasonable accommodations or 

modifications. By way of further answer, and pursuant to Fed. R. Civ. P. 33(d), Defendant 

asserts that its policies are described in the documents it is producing in response to Plaintiff’s 

request to produce. 

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. 

ANSWER: Defendant objects to this interrogatory as it overly broad and unduly burdensome 

and seeks information that is irrelevant to this action and not reasonably calculated to lead to the 

discovery of admissible evidence. Without waiving these objections, Defendant refers Plaintiff to 

its eligibility policies and employee training materials that it is producing to Plaintiff.

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. 

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ANSWER: Defendant objects to this interrogatory as it vague and ambiguous and seeks 

information that is irrelevant to this action and not reasonably calculated to lead to the discovery 

of admissible evidence. Without waiving these objections, Defendant refers Plaintiff to its 

eligibility policies and employee training materials that it is producing to Plaintiff. 

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. 

ANSWER: Defendant objects to this interrogatory as it vague and ambiguous and seeks 

information that is irrelevant to this action and not reasonably calculated to lead to the discovery 

of admissible evidence. Without waiving these objections, Defendant refers Plaintiff to its 

eligibility policies and employee training materials that it is producing to Plaintiff, and to the 

information available on its website: https://www.cslplasma.com/become-a-donor . 

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. 

ANSWER: Defendant objects to this interrogatory as it overly broad and unduly burdensome 

and seeks information that is irrelevant to this action and not reasonably calculated to lead to the 

discovery of admissible evidence. Without waiving these objections, Defendant refers Plaintiff to 

its eligibility policies and employee training materials that it is producing to Plaintiff. 

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. 

ANSWER: Defendant objects to this interrogatory as it overly broad and unduly burdensome 

and seeks information that is irrelevant to this action and not reasonably calculated to lead to the 

discovery of admissible evidence. 

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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. 

ANSWER: Defendant objects to this interrogatory as it overly broad and unduly burdensome 

and seeks information that is irrelevant to this action and not reasonably calculated to lead to the 

discovery of admissible evidence. Without waiving these objections, Defendant refers Plaintiff to 

its eligibility policies and employee training materials that it is producing to Plaintiff. 

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

deferred and state the reason for deferral. 

ANSWER: Defendant objects to this interrogatory as it overly broad and unduly burdensome 

and seeks information that is irrelevant to this action and not reasonably calculated to lead to the 

discovery of admissible evidence. 

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

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

ANSWER: Defendant objects to this interrogatory as it overly broad and unduly burdensome. 

Without waiving this objection, Defendant states: undersigned counsel and Eric Silberstein, Lead 

Counsel, Operations.

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DATED: February 8, 2021 Respectfully submitted, 

CSL PLASMA INC. 

BY: ________________________________ 

WLENYENO ELLIOTT-BROWNE

DIVISION DIRECTOR

For purposes of objection, 

Jennifer L. Colvin (ARDC No. 6274731)

Eric A. Berg (ARDC No. 6209624) 

OGLETREE, DEAKINS, NASH, 

SMOAK & STEWART, P.C. 

155 North Wacker Drive 

Suite 4300 

Chicago, Illinois 60606 

Telephone: 312.558.1220 

jennifer.colvin@ogletree.com

eric.berg@ogletree.com

By: /s/ Eric A. Berg

One of the Attorneys for Defendants 

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CERTIFICATE OF SERVICE 

I hereby certify that, on February 8, 2021, I caused Defendant CSL Plasma Inc.’s Answers to 

Plaintiff’s First Set of Interrogatories to be served via electronic mail and First Class Mail upon the 

following. 

Neil Kelley 

Elizabeth Morris 

Judith Levitan 

Kathryn Hunt Muse 

Office of the Illinois Attorney General 

100 West Randolph Street, 11th Floor 

Chicago, Illinois 60601 

Telephone: 312.814.3000 

nkelley@atg.state.il.us 

emorris@atg.state.il.us 

jlevitan@atg.state.il.us 

kmuse@atg.state.il.us 

Attorneys for Plaintiff THE STATE OF ILLINOIS

 /s/ Eric A. Berg 

One of the Attorneys for Defendants 

CSL PLASMA, INC. and CSL BEHRING, LLC

45800160.4 

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