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23 questions
Rhoads v. City of Chicago (16‑cv‑07621)
Letter from City of Chicago Department of Law
Date: March 22, 2017
To: Timothy Rhoads
3753 N. Francisco Ave.
Chicago, IL 61206
seth@solarblu.net
Re: Rhoads v. CPD, et al., 16 CV 07621
Dear Mr. Rhoads,
This letter is regarding your discovery request to Defendant Gonzales (filed Document #79). Your request for discovery contains 57 interrogatories. Pursuant to Rule 33 of the Federal Rules of Civil Procedure, unless you seek leave of court, you are limited to only 25 interrogatories. Please identify the 25 interrogatories for which you are requesting a response.
As a reference to the document referred to above, enclosed is a copy of your discovery request to Defendant Gonzales (Document #79).
Sincerely,
Jessica D. Ziswana
Assistant Corporation Counsel
30 N. LaSalle Street, Suite 900
Chicago, Illinois 60602
jessica.ziswana@cityofchicago.org
Interrogatories Submitted by Plaintiff
Case: 1:16‑cv‑07621 | Document #79
Date Filed: March 13, 2017
First Set of Discovery Questions
Plaintiff Timothy Rhoads, under duress, requests Defendant Gonzales answer the following interrogatories:
- Is it common for you to feel threatened when dealing with a member of the LGBTQ community?
- Is it common for you to ask a person on the phone, “If I beat the shit out of you while you’re in cuffs, what do you call it?”
- Is it common for you to harass and intimidate the complainant?
- Is “Jackhammer” one of your clients, or do you have previous experience servicing them? List all interactions in your career.
- Is it common for you to see someone get attacked and tell them, “You were flailing like a faggot. You deserved to get your ass beat”?
- Is it common for you to come to someone’s house, arrest them, hold them for 7 hours, and tell them you are the judge and jury?
- How many times have you visited Mr. Rhoads’ websites, LinkedIn profile, or other social media?
- Is it common for you to submit perjurious comments to your supervisor to get charges on a civilian taxpayer?
- When was the last time you took a lie detector test? What was the case number and result? Provide technical details.
- What was the last phone harassment complaint before Mr. Rhoads? Provide details and status.
- Do you have any disabilities or mental disorders?
- Do you have a problem listening to others or interacting with those who disagree with you?
- Would your coworkers describe you as a nice person?
- Do you let your badge get to your head?
- Have you ever been accused of excessive force, domestic violence, or bullying?
- Do you have cases pertaining to such violent events in your lifetime?
- Are you recovering from any addictions?
- Can you run around the block without passing out? Are you physically fit for duty?
- Is it common for you to lie to cover your actions or bully a complainant?
- Have you ever been stripped of your duties or put on administrative duty? Why?
- Is it typical for you to suspend a case because a victim didn’t present “in a reasonable manner”?
- Do you receive any kickbacks or illegal money from bars or outside sources?
- Would your supervisor Emiliano Leal say you are fair and level-headed in dealing with the community?
- Do you provoke prisoners in lock-up?
- Do you have children or a family?
- Are you a closet homosexual or a gay-bashing homosexual? Do you gay-bash LGBTQ members?
- Do you retaliate against LGBTQ individuals because of personal issues?
- Are you currently on online dating? If so, which platforms?
- Did you know you spelled your name wrong on LinkedIn?
- What is your IQ, height, and weight? Have you been overweight long?
- Have you ever been arrested? What high school did you attend?
- Do you wear a body cam? Do you turn it off or coerce officers to believe your version of events?
- Do you use your position for personal favors?
- How would your family be affected if you lost your job, star, and licenses?
- Do you know Joe Starcher or anyone in the web hosting industry?
- Do you read Mr. Rhoads’ federal filings? How have they affected your fairness toward him?
- Have you arrested anyone related to Mr. Rhoads’ April 23, 2016 complaint? If not, why not?
- What type of job will you have if you lose your badge and certifications?
/s/ Timothy Rhoads
3753 Francisco Ave.
Chicago, IL 60618
Email: seth@solarblu.net
Dated: March 10, 2017
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