Escolar Documentos
Profissional Documentos
Cultura Documentos
Defense counsel takes the position that these two document requests, and any surveillance of
Plaintiffs by the NYPD, are outside the scope of discovery. Plaintiffs counsel takes the position
that the surveillance had no legitimate basis and constitutes retaliation. In Plaintiffs view, acts of
retaliation would compound the unlawful conduct alleged in the complaint, might be seen by a
jury as an attempt to intimidate Plaintiffs and cause them to discontinue pursuing their rights in
this Court and may substantiate the claim for punitive damages. Plaintiffs submit this discovery
request fits squarely within the parameters or FRCP 26(b) as it is reasonably calculated to lead
to the discovery of admissible evidence.
Thank you for your consideration of this matter.
Respectfully submitted,
/s/
Norman Siegel
Herbert Teitelbaum
Sharon Sprayregen
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