Sample Interrogatories, Document Requests and Request for Admissions in an FMLA case from the Plaintiff’s side.
e-Legal form in Word format – 31 pages
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Sample FMLA interrogatory requests
1. Please state whether you employed 50 or more employees at your facility located at (address) for 20 or more calendar workweeks during the calendar year in which the plaintiff suffered the adverse action at issue (or define fmla violation) and whether you did so during the preceding calendar year.
2. If your response to the previous interrogatory was in the negative as to both or either years in question, please list for each calendar week of each year in question the names of all employees who appeared upon your payroll whether or not they received compensation or actually worked during the week in question.
3. Please list all facilities (and their corresponding addresses) located within a 75 mile radius of the address set forth in Interrogatory #__ and for each facility please indicate how many employees were employed there for 20 or more calendar workweeks during the calendar year in which the plaintiff suffered the adverse action at issue (fmla violation) as well as for the preceding calendar year.
4. Please set for the Plaintiff’s hire date; positions with the Defendant; pay rate and/or salary in each position; time in each position; reasons for changes in positions throughout Plaintiff’s employment; and supervisor’s in each position.
Sample FMLA document requests
- REQUEST NO. 1
Produce each and every document that shows basic payroll and identifying employee data, including name, address, and occupation; rate or basis of pay and terms of compensation; daily and weekly hours worked per pay period; additions to or deductions from wages; and total compensation paid to the plaintiff for the past years.
REQUEST NO. 2
Produce each and every document reflecting dates FMLA leave was taken by the Plaintiff including time records, requests for leave, and similar documentation.
REQUEST NO. 3
Produce each and every document that reflecting employee notices of leave furnished to the Plaintiff under the FMLA and copies of all general and specific notices given to the Plaintiff and other employees as required by the FMLA and its regulations.
31 pages of FMLA form discovery requests – interrogatories, document requests and admissions