Rendered from the court's authenticated repository
Searchable full text
2,336 characters extracted
—
RIDGEWAY ADMINISTRATIVE COURT
YASSEN28,
Plaintiff,
v.
RIDGEWAY NATIONAL GUARD;
CONSTANTLYVERBAL, in their
official capacity as Captain of the
Ridgeway National Guard;
BOHBAZINGA, in their official
capacity as Adjutant General of the
Ridgeway National Guard,
Defendant.
Case No. RSC-AD-619
PLAINTIFF MOTION FOR
DISCOVERY
MOTION FOR DISCOVERY
Plaintiff, in the above entitled matter, moves to discover the items listed below in
accordance with Rid. R. Civ. P. 19. None of the items requested are privileged, and are relevant
to this court’s disposition of the claims before it.
1. Any instructions, policies, procedures, directives, orders, whether written, verbal or
otherwise, instructing staff of any capacity about how to administer the law or policy
with regard to background checks in application cycles.
2. The reason for the failed background checks for each individual that failed the
background check in the latest application cycle, of which Plaintiff here was a part of.
3. Any evidence associated with the failed background checks for each individual that failed
the background check including, but not limited to, evidence that the inventory is closed,
a copy of the conviction, evidence of association with criminal or terrorist organizations,
or otherwise as applicable.
4. The mechanism used to obtain the Plaintiff’s alleged moderation history.
5. The name of the individual who obtained the Plaintiff’s alleged moderation history.
6. All of the evidence used as a basis to deny the Plaintiff’s background check.
7. The name of the individuals directly responsible for denying the Plaintiff’s background
check, and for any individuals who administered the background checks for any of the
applicants.
8. The contact information of the individuals responsible for administering the background
checks for the Plaintiffs and all other applicants in the latest cycle.
9. The basis used as the determination that the accounts of applicants were alternate
accounts.
10. The name of the main or alternate accounts of the applicants that were denied for that
basis.
11. A copy of the Plaintiff’s application, in full, as submitted.
12. Any discussions related to the denial of the Plaintiff’s application on the basis of his
background check or otherwise.
Dated: August 13, 2022 Respectfully submitted.
CLIFFORD2
Counsel
10 000
Document record
File size
105.7 KB
Uploaded
Aug 10, 2022 12:00 PM
Filed
Aug 10, 2022 12:00 PM
Filing code
ADMINISTRATIVE_APPLICATION
Uploaded by
yassen28, et al.
Notes
Yassen28 motion for discovery.pdf — archived from the Trello docket (https://trello.com/c/u9gQG4RS)
