COURT OF COMMON PLEAS
FAIRFIELD COUNTY, OH
ROBERT A. NEINAST
Plaintiff,v.BOARD OF TRUSTEES OF THE FAIRFIELD COUNTY DISTRICT LIBRARY,
Defendants.
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Case No. 09 CV 0657
Judge Martin
Comes the plaintiff Robert A. Neinast, acting pro se, and propounds his second set of interrogatories pursuant to Rule 33 of the Ohio Rules of Civil Procedure. The Plaintiff asks that the Defendants answer the interrogatories within twenty-eight (28) days of service.
The instructions contained within Plaintiff’s First Set of Interrogatories and Request for Production of Documents are hereby considered fully rewritten herein.
INTERROGATORIES INTERROGATORY NO. 20:
Based upon the discussions of the Board at their January, 2009 and February, 2009 meetings, what was the specific reason or reasons that the footwear policy was upheld and supported by the vote in the February meeting?
RESPONSE:
Discussion involved the major reason that the Board has the authority to promulgate rules for the proper operation and management of the Library which includes the creation and enforcement of a dress code. Discussion involved the minor reason that the Board wishes to reduce the risks of injury to patrons which has the major effect of maintaining fiscal responsibility, which leads to upholding a dress code policy that, among other things, requires patrons to wear shoes.
INTERROGATORY NO. 21:
Neinast used the Fairfield County District Library (or a branch location thereof) barefoot on November 26, 2007, December 12, 2007, April 10, 2008, and April 23, 2008. Did Neinast’s barefoot presence on those days in any way disrupt the Library environment? If so, in what way?
RESPONSE:
Assuming for the sake of argument that Neinast used the Fairfield County District Library facilities on the dates in question, Neinast's barefoot presence did not disrupt the Library environment.
INTERROGATORY NO. 22:
On those days that Neinast used the Fairfield County District Library barefooted, is there any evidence that his barefootedness placed the other patrons in any danger? If so, in what way?
RESPONSE:
Assuming for the sake of argument that Neinast used the Fairfield County District Library facilities on the dates in question, Neinast's barefootedness did not place other patrons in danger.
Respectfully submitted,
_______________________
Robert A. Neinast
Plaintiff, pro se
8617 Ashford Lane
Pickerington, OH 43147
Phone: (614) 759-1601
Email: neinast@att.net
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing was served, by regular U.S. mail, upon Roy E. Hart, Assistant Prosecuting Attorney, Attorney for Defendants, 201 South Broad Street – Suite 400, Lancaster, OH, 43130, this 10th day of August, 2009, with an electronic copy (Word) on disc included in the same envelope.
_______________________
Robert A. Neinast
Plaintiff, pro se