IN THE COURT OF COMMON PLEAS OF FAIRFIELD COUNTY, OHIO

Robert A. Neinast Plaintiff, -vs- Board of Trustees of the Fairfield County District Library, Defendant.

: : : : : : : : :

CASE NO. 2009-CV-0657 JUDGE CHRIS A. MARTIN

DEFENDANT'S OBJECTIONS TO PLAINTIFF'S INTERROGATORIES

Now comes Defendant who objects to Plaintiff's Interrogatories as follows:

Interrogatory No. 13:

Do you contend that bare feet on a patron are in any way disruptive of the Library environment, or represent a danger to any other patrons? If so, in what way? And if so, how are flip-flops not equally disruptive or dangerous?

Answer:

Object as interrogatory calls for speculation

Interrogatory No. 15:

Is it possible that a patron, in reaching up for a book or books on a higher shelf, could have a book drop down upon his or her head, or onto his or her foot? If so, is it your contention that proper operation and management of the Library would include making a rule that all patrons wear hard hats or steel-toed shoes? And if so, in what way?

Answer:

Object as interrogatory calls for speculation

Interrogatory No. 16:

Is it possible for a patron wearing high-heeled shoes to catch one of those heels in the carpeting, to twist his or her ankle due to the height of the heel and/or some minor defect in the floor of the Library, or to otherwise injure him- or herselves while in the Library? If so, is it your contention that proper operation and management of the Library would include making a rule that banned high heels? And if so, in what way?

Answer:

Object as interrogatory calls for speculation

Interrogatory No. 17:

It is possible that a patron might be infected with the H1N1 influenza virus which could then be spread to other Library patrons? It is your contention that proper operation and management of the Library would include requiring that every patron, before entering the Library, provide proof of vaccination against that virus? If so, in what way?

Answer:

Object as interrogatory calls for speculation

Interrogatory No. 18:

Is it your contention that the conditions in the Library regarding barefoot use are different than the conditions in the Fairfield County Hall of Justice and the Ohio Statehouse? If so, please detail the differences that justify a shoe rule as part of the proper operation and management of the Library.

Answer:

Object as interrogatory calls for speculation

VERIFICATION

STATE OF OHIO	)
COUNTY OF FAIRFIELD	) SS:

Roy E. Hart, Assistant Prosecuting Attorney of Fairfield County, Ohio, Attorney for Defendant, Board of Trustees of the Fairfield County District Library, being sworn, says that the answers to the foregoing Interrogatories are true as he believes as to the Objections to said Interrogatories.

___________________________ Roy E. Hart (0023826) Assistant Prosecuting Attorney Attorney for Defendant, Boart of Trustees of the Fairfield County District Library 201 South Broad Street — Suite 400 Lancaster, Ohio 43130 740-653-4259 or 614-837-2699 Fax 740-553-4708

Sworn to and acknowledged before me and subscribed in my presence this 29th day of September, 2009.

___________________________ Notary Public — State of Ohio Lynette K. Barnhart

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a copy of the foregoing Defendant's Objections to Plaintiff's Interrogatories was sent by ordinary U.S. mail, postage prepaid, to Robert A. Neinast, acting pro se, at his address of 8617 Ashford Lane, Pickerington, Ohio 43147, this 29^th day of September, 2009.

Roy E. Hart (0023826) Assistant Prosecuting Attorney Attorney for Defendant