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IN THE UNITED STATES DISTR1CT COURT FOR THE WESTERN DISTRICT OF LOUISIANA
SHREVEPORT DMSION

NEW BETHANY HOME FOR GIRLS, ET AL ..

VERSUS

CIVIL ACTION NO. 96-2065

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JUDGE DON ALD WALTER

MAGISTRATE JUDGE PAYNE STATE OF LOUISIANA, ET AL

.OBJECTIONS AND RESPONSES TO DEFENDANTS FIRST SET OF

INTERROGATORIES NOW INTO

COURT,

through undersigned

counsel,

come Plaintiffs propounded

who

respectfully them.

respond to the Defendants First Set of Interrogatories

upon

INTERROGATORY

NO.1:

Please state your full legal name, your full legal name at birth (if different from your present name), your date of birth, your place of birth, and your social security number.
RESPONSE TO INTERROGATORY

NO.1; date of birth is October 29, 1960. He was

Frank Javier Garcia.

Mr. Garcia's

born in San Juan, TX. His social security no. is 452-23-1658.

INTERROGA TORY NO.2:

Please identify all banks or other financial institutions in which you now have, or have had at any time since January I, 1992, any funds or other assets, or at which you now have, or have had at any time since January 1, 1992, any type of account (whether

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checking, savings, share-draft, NOW account, certificate of deposit, money market account, trust fund, or any other type of account of any sort whatsoever). RESPONSE TO INTERROGATORY NO.2;

Mr. Garcia has no bank accounts .

INTERROGATORY

NO.3: No.

For each bank or financial institution listed by you in your answer to Interrogatory

2, please state the type of account or accounts at each, the account number or numbers. and (if the account is inactive) the date the account was closed. For each such account,

please identify all signatories to such accounts or any other persons authorized access funds held in such accounts. RESPONSE TO INTERROGATORY NO.3:

Not applicable. INfERROGATORY NO.4:

Please state precisely and in detail each and every act or failure to act by which you allege defendant Vickie Haynes caused any injury to you. For each such act or failure
to act, state the date or occasion on which the act or failure to act occurred.

state

precisely and in detail the injury or damage you claim to have suffered, and state precisely and in detail the manner in which the act or failure to act caused the injury 'or damage. RESPONSE TO INTERROGATORY NO.4:

This interrogatory is no longer applicable to Mr. Garcia because he is no longer a party plaintiff in this action.

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INTERROGATORY

NO. S:

Please state precisely and in detail each and every act or failure to act by which you aUege any of the other defendants caused any injury to you. For each such act or

failure to act, state the date or occasion on which the act or failure to act occurred, state precisely and in detail the injury or damage you claim to have suffered. and state precisely and in detail th manner in which the act or failure to act caused the injury or damage. RESPONSE TO INTERROGATORY NO.S;

This interrogatory is no longer applicable to Mr. Garcia because he is no longer a party plaintiff in this action. INTERRQGATORY NO.6:

Please identify all children or other persons under the age of eighteen years over whom you have exercised any custody, control or supervision at any time during your

employment at New Bethany.

For each child or other person so identified. please state control or supervision. For

the dates during which you exercised such custody, purposes of this Interrogatory.

a person is deemed a child if. at any time during which

that person was under your custody. control or supervision. that person had not yet reached his or her eighteenth birthday. RESPONSE TO INTERROGATORY NO.6:

Mr. Garcia does not have a list of all children in which he exercised custody, control or supervision during his employment at New Bethany. However. New

Bethany should have in its possession flies which would identify all such persons. Those files will be made available for the Defendants' inspection and copying as and

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where such documents are kept in the ordinary course of its business during normal business hours and at a time mutually agreeable between Defendants' Plaintiffs' counsel. Respectfully submitted, counsel and

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DAVIDSON. NIX & JONES A Professional Law Corporation

509 Market Street. Suite 800 Shrevepon, Louisiana 71101 (31 4244342

and

Billy Rex Harper, Jr., Bar No. 18613

LAW OFACE OF BD...L Y REX HARPER, JR: 113 North Myrtle Street Arcadia, Louisiana 71001-3414
(318) 263-9017

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CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing has been served upon the following . -parties: Henry M. Bernstein., Esq. Louisiana Department of Justice, Litigation Division . 330 Marshall Street, Suite 777 Shreveport, LA 71101 Wayne R. Crouch, Esq. Legal Section Department of Public Safety P.O. Box 6614 Baton Rouge, LA 70896 by placing a copy of same in the U.S. Mail, properly addressed, postage prepaid. Shreveport, Louisiana, this Anthony C. Caruso, Esq. Department of Social Services Bureau of General Counsel P.O. Box 1887 Baton Rouge, LA 70821

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of January, 1997.

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