Identify and state in detail the exact reasons why [Bobbitt, Thorpe, Liebe, Drodz, Koehler, Nichols and Kilby] were promoted to the position of Master Sergeant during the period of 1997–1999 instead of Plaintiff Byers.... In addition, state every reason why these individuals were considered to be “more prepared,” and/or “the better candidate,” and/or “more qualified” for promotion to the position of Master Sergeant than Plaintiff Byers.
All personnel documents or files, evaluative documents, rating documents, work assignments, computer files and/or e-mail files, payroll documents, benefit documents, EEO files, investigatory files, promotional documents, grievance files, supervisory files, district files, in-house legal files or any other type of document or file maintained with respect to [Gainer, Marlin, Yokley, Kent, Johnson, Sloman, Bouche, Comerie, Erlenbush and Thorpe].
All studies, reports reviews and/or analysis in underlying data in databases thereof generated, including but not limited to, any maintained in computers done by internal staff consultants, government agencies, or others related to any employment practices, policies, procedures, or statistics of Defendants [ISP] that deals with or reflects gender equity together with all underlying source material from which the data and databases were prepared and all memorandum and correspondence referring or relating thereto.
All documents provided to or received from any expert witness, consultant, investigator, and/or any other agent, and any report or documents prepared, authored or drafted by such expert witness, consultant, investigator, or agent which in respect relates in any way to the treatment of women, including but not limited to, promotions, pay, working conditions, and hostile work environment.
End of Document.