Documentation to "My Case"

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UNITED STATES FEDERAL DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
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TIBOR GASPARIK,...........................................................................CV-05-03817 (SJF/ARL)
Plaintiff,
………………………………………………………….................................………..DEFENDANT’S RESPONSE
-against-
…………………………………………………………................................………...TO INTERROGATORIES
STONY BROOK UNIVERSITY,
Defendants.
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Defendant STONY BROOK UNIVERSITY, (“Stony Brook”) by its attorney, ELIOT SPITZER, Attorney General of the State of New York, pursuant to Rule 33 of the Federal Rules of Civil Procedure, hereby respond to the Interrogatories posed by plaintiff as follows:

The responses set forth herein are made without waiving the following:
a) The right to object on the grounds of competency, privilege, relevancy, materiality, or any other proper ground, to the use of any material produced herein, in whole or in part, for any purpose, in any subsequent proceeding in this action or in any other action;
b) The right to object on any or all grounds, at any time, to other requests or other discovery procedures involving or relating to the subject matter of the requests responded to herein;
c) The right at any time to revise, correct, modify, supplement or clarify any of the responses provided herein; and
d) Any defenses to be asserted by defendant Stony Brook in any Motion to Dismiss the Complaint under FRCP 12 or in any Verified Answer.
All of defendant’s responses are made subject to the foregoing objections, comments and qualifications.

General Response

With respect to the request of the Plaintiff that the interrogatories by served upon the fourteen faculty members listed in the demand, the Defendant states the following:
Said interrogatories will not be served upon any employee of the Defendant as such “service” is not required of the Defendant under any applicable statute, case law or the F.R.C.P.

Response to Interrogatories 2 through 25

Defendant objects to each and every one of these interrogatories as irrelevant, overbroad, and unduly burdensome, and the probative value of any of the information which may be provided by the Defendant in response to these interrogatories would be substantially outweighed by the danger of unfair prejudice, confusion of the issues, would constitute undue delay, waste of time, present a needless presentation of cumulative evidence, would constitute inadmissible hearsay, and would constitute an impermissible invasion of privacy.

Dated: Hauppauge, New York
February 6, 2006

Yours, etc.
ELIOT SPITZER
Attorney General for the State of New York
Attorney for Defendant SUNY Stony Brook

by: __________________________
Lori L. Pack (8303)
Assistant Attorney General
300 Motor Parkway, Suite 205
Hauppauge, New York 11788

To: Tibor Gasparik, Plaintiff pro se
352 Plad Blvd.
Holtsville, N.Y. 11742