1437 Bannock St . Denver , Colorado 80202 - Brennan Center for ...

:.INTERROGATORY N0.1: Identify the person who answers these Interrogatories,and if more than one person supplies the information or answers these Interrogatories, pleasestate the person who answered which portion of each Interrogatory.. Objection: Interrogatory No. 1 is unduly burdensome to the extent that it requires theSecretary to state the person who answered which portion of an Interrogatory when more thanone person supplied the information or answer to the Interrogatory.Secretary's answer: Subject to and without waiving the objection, the Secretarysubmits the following answer. Each answer to Interrogatories Nos. 3-26 identifies the person orpersons who supplied the information or answers to the Interrogatory.INTERROGATORY NO.2: State the names and addresses of all persons who have orclaim to have any information concerning the fact relevant to this litigation and state in completedetail the substance and nature of such information.Objection: Interrogatory No. 2 is overbroad and unduly burdensome to the extent itseeks information relevant to claims, issues and counterclaims in this litigation raised bydefendants- intervenors Ortiz and Common Cause. Defendant Johnson is not entitled to seekdiscovery on claims, issues or counterclaims that are unique to these other parties. In addition,the Secretary objects to the extent that the Interrogatory seeks information subject to theattorney-client privilege.Secretary's answer: Subject to and without waiving the objection, the Secretarysubmits the following answer. The following employees have information relevant to the claimsmade by the Secretary against Defendant Johnson and the defenses raised by Defendant Johnson:Judd Choate, Wayne Munster, Hilary Rudy, Vicky Stecklein, Ben Schier, Richard Coolidge,Andrew Cole, William Hobbs, Gary Zimmerman, and Secretary of State Scott Gessler. Thebusiness office for each is 1700 Broadway, Denver, Colorado 80202. In addition, DefendantJohnson and members of her staff have information relevant to this litigation. The information isset forth in the answers to these interrogatories.INTERROGATORY NO. 3: Describe the processes, steps, or actions you took tosupervise pre-election practices related to or concerning the conduct of the Election including butnot limited to processes, procedures, or other actions related to or concerning the conduct of theElection as a mail ballot election.Objection: Interrogatory No. 3 is overbroad and unduly burdensome to the extent that itseeks information about practices related to all aspects of the conduct of the Election, as defmedin the interrogatories. The Secretary's claims against Defendant Johnson and DefendantJohnson's defenses relate solely to actions taken by the Secretary and Defendant Johnson withregard to the Secretary's interpretation of statutes and rules governing the mailing of ballots inmail ballot elections to voters who are designated as "inactive failed to vote." The Interrogatory2Exhibit A