LEONARD HARP, et al.

*
* IN THE CIRCUIT COURT
Plaintiffs * FOR
* BALTIMORE CITY
v. *
*
GOVERNOR LARRY HOGAN , et al. *
STATE OF MARYLAND *
100 State Circle *
Annapolis, MD 21401 *
* Case No.: 24-C-21-2999
Defendant *
*
* * * * * * * * * * * * *

PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS

DEFENDANT TIFFANY ROBINSON

INSTRUCTIONS

Plaintiffs Leonard Harp, et al. (“Plaintiffs”), by undersigned counsel, propound the

following First Set of Requests for Production of Documents to Defendant Tiffany Robinson.

Pursuant to Md. Rule 2-422(b), your responses are due within thirty (30) days after service of

these Requests. If you intend to withhold any requested document on the basis of privilege,

other than a document created by you in the course of and in connection with this litigation or a

confidential communication between you and your attorney in connection with this litigation,

please identify the withheld document by stating its date, the type of document, and the general

subject matter of the document, and please state the privilege asserted.

These Requests are continuing in nature pursuant to Md. Rule 2-401(e) and require you

to produce any new, different, or otherwise relevant documents that may exist or come into

possession of you from the date of initial production through trial in this matter.

If you perceive any ambiguities in any Request, instruction, or definition, set forth the

matter deemed ambiguous and the construction used in your response.

DEFINITIONS
In these Requests, the following definitions apply:
 (a) The words “any” and “all” shall be read in the conjunctive and not in the
disjunctive wherever they appear, and neither of these words shall be interpreted to limit the
scope of an Interrogatory. Furthermore, the use of a verb in any tense shall be construed as the
use of the verb in all other tenses, and the singular form shall be deemed to include the plural,
and vice-versa. The singular form of any noun shall be deemed to include the plural, and vice-
versa.
(b) “Document” includes electronically stored information and any writing,
drawing, graph, chart, photograph, sound recording, image, and other data or data
compilation stored in any medium from which information can be obtained and translated, if
necessary, through detection devices into reasonably usable form.
(c) “Person” includes an individual, general or limited partnership, joint stock
company, unincorporated association or society, municipal or other corporation, incorporated
association, limited liability partnership, limited liability company, professional corporation,
the State, an agency or political subdivision of the State, a court, and any other governmental
entity.
(d) The terms “you” and “your” refer to Maryland Secretary of Labor Tiffany M.
Robinson, together with any attorneys, agents, representatives, or persons acting on behalf of
any of the foregoing.

(e) “Agreement” refers to the Agreement Implementing the Relief for Works
Affected by Coronavirus Act between the State of Maryland and the Secretary of Labor, U.S.
Department of Labor.
(f) “CARES Act Benefits” refers to the unemployment insurance benefits provided
through the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act, codified as 15
U.S.C. 9001 et seq.
(g) “State” refers to the State of Maryland.
(h) Unless otherwise specified, these Requests refer to the alleged acts, omissions,
and occurrences described in the Complaint filed in this matter.

REQUESTS FOR PRODUCTION OF DOCUMENTS

1. Please provide all communication, electronic or written, between all any and all
Department of Labor Employee and any and all customer service quality evaluation
vendors per Labor and Employment Article §8-109(a)(3) of the Maryland Annotated
Code.
2. Please provide any and all manuals, handbooks, directives, policies, memorandums, rules
and/or regulations regarding the processing of claims for CARES Act Benefits.
3. Per Interrogatory number five, please provide any and all manuals, handbooks, directives,
policies, memorandums, rules and/or regulations regarding when or for what reasons
 claimants are required to reapply for an initial determination of CARES Act Benefits
eligibility.
4. Provide any and all contracts or agreements between the Department of Labor and any
and all customer service quality evaluation vendors.
5. Please provide any and all manuals, handbooks, directives, memorandums, policies, rules
and/or regulations produced by the Department of Labor regarding the requirements
established in Labor and Employment Article §8-109(a)(4) of the Maryland Annotated
Code.
6. Please provide any and all manuals, handbooks, directives, memorandums, policies, rules
and/or regulations produced by the Department of Labor regarding the requirements
established in Labor and Employment Article §8-109(a)(5) of the Maryland Annotated
Code.
7. Please provide any and all manuals, handbooks, directives, memorandums, policies, rules
and/or regulations produced by the Department of Labor regarding the requirements
established in Labor and Employment Article §8-109(a)(7) of the Maryland Annotated
Code.
8. Please provide any and all manuals, handbooks, directives, memorandums, policies, rules
and/or regulations produced by the Department of Labor regarding the requirements
established in Labor and Employment Article §8-109(a)(8) of the Maryland Annotated
Code.

Respectfully submitted,

UNEMPLOYED WORKERS UNION

____________________________
Alec Summerfield, CPF #1906060002
2011 N. Charles Street
Baltimore, MD 21230
(443) 324-8644
Asummerfield@protonmail.com
 CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing first set of requests for document production

was mailed this 14th day of September, 2021, by certified, postage prepaid, United States Mail,

on:

Christopher R. Mellott
CRMellott@Venable.com
Geoffrey R. Garinther
GRGarinther@Venable.com
Ashleigh J. F. Lynn
AJLynn@Venable.com
Elizabeth C. Rinehart
LCRinehart@Venable.com
Anthony J. Vitti
AJVitti@Venable.com
Venable LLP 750 E. Pratt Street, Suite 900
Baltimore, Maryland 21202

Attorneys for Defendants

ALEC SUMMERFIELD, CPF #1906060002

Pro Bono Attorney
Unemployed Workers Union
2011 N. Charles Street
Baltimore, MD 21218
(443) 324-8644