UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

August Banaza
Plaintiff
v.
Officer Smith and
Village of Kenilworth
Defendants
PLAINTIFF AUGUST BANAZAS FIRST SET OF INTERROGATORIES
Pursuant to Rule 33 of the ederal Rules of !ivil Procedure" Plaintiff August Banaza #$
their undersigned counsel" re%uests that the Defendants answer the following interrogatories.
INTERROGATORIES
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,. As to Defendant Officer Smith/s em0lo$ment and em0lo$ments histor$" answer-
A. the length of time at $our 0resent em0lo$ment1
B. the names and addresses of all $our em0lo$ers during the 0ast ten 2,3. $ears1
!. the dates of each em0lo$ment1
D. the nature of each em0lo$ment1
). the average wee4l$ wages of each em0lo$ment1 and
. the reasons for termination of each em0lo$ment.
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5. Defendant Officer Smith" state $our height" weight" the nature of an$ 0h$sical games or s0orts
in which $ou regularl$ engage and the num#er of times wee4l$ $ou engage in active e6ercise and
or strength training.
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3. Defendant Officer Smith" state whether $ou" on an$ occasion within five 27. $ears 0rior to the
occurrence" #ecame involved in an$ fight" argument" altercation" or have ever #een cited" fined"
0enalized" demoted" or otherwise re0rimanded in which #lows were struc4 or where threats were
e6changed with a citizen during a traffic sto0 while $ou were an active dut$ officer for the
Village of Kenilworth" and if so" state-
A. the nature of each incident1
B. the 0lace where each incident occurred1 and
!. the names of all 0arties involved in each incident and their 0resent addresses or
wherea#outs" if 4nown.
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8. Defendant Officer Smith" 0rior to the occurrence" state whether $ou ever uttered an$ threats to
commit 0h$sical violence on the 0laintiff or to an$one other than the 0laintiff while on active
dut$ with for the 0olice de0artment for the Village of Kenilworth" and if so" state-
A. the 0erson or 0ersons to whom $ou uttered the threats1
B. the time and 0lace that each threat was uttered1 and
!. what $ou said on each occasion.
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7. Defendant Officer Smith" state whether $ou have ever #een arrested and charged with the
crime of assault and #atter$" whether on dut$ or off" and" if so" state-
A. the date of each arrest1
B. where each arrest occurred1 and
!. whether $our arrest in each case resulted in a conviction" an ac%uittal" dismissal of
charges" or other dis0osition of the charges against $ou.
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9. Defendant Village of Kenilworth" identif$ and descri#e the training or e60erience re%uired for
an a00ointment as an officer of the 0osition currentl$ held #$ Defendant Officer Smith.
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:. Defendant Village of Kenilworth" descri#e an$ educational re%uirements for a00ointment as a
0olice officer in the 0osition currentl$ held #$ Defendant Officer Smith.
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;. Defendant Village of Kenilworth" identif$ and descri#e an$ suits or com0laints" #oth formal or
informal" written or oral" #rought against Officer Smith" charging him with a#use of his lawful
authorit$" or use of e6cessive force during his em0lo$ment with the Village of Kenilworth Police
De0artment.
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<. Defendant Village of Kenilworth" identif$ and descri#e an$ actions ta4en #$ $ou" $our
su0ervisor" an$ investigative #od$" or court with res0ect to an$ of the com0laints identified in
res0onse to the 0receding interrogatories.
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,3. Defendant Village of Kenilworth" descri#e an$ internal administrative 0rocedures in
e6istence" on or 0rior to the occurrence" to investigate" 0revent" or determine instances of a#uses
of authorit$ or e6cessive use of force #$ 0olice officers in the Police De0artment.
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,,. Defendant Village of Kenilworth" &dentif$ and descri#e all 0olice memoranda" documents"
circulars" #ulletins" manuals" and general orders of an$ 4ind that indicate the amount of force that
is 0ermissi#le in arresting an individual for sus0icion of driving under the influence.
DA()D- 'OV)=B)R ,," 5338 B$->>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>
Vincent !havarria
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797 ?. Adams
!hicago" &@ 93,39
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