Case: 1:18-cv-02069 Document #: 45-2 Filed: 03/01/19 Page 1 of 22 PageID #:468

IN THE UNITED STATE DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
ALAINA HAMPTON,
Plaintiffs,
v.
DEMOCRATIC PARTY OF ILLINOIS,
FRIENDS OF MICHAEL J. MADIGAN,
DEMOCRATIC MAJORITY and 13TH WARD
DEMOCRATIC ORGANIZATION,
Defendants.

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Case No. 1:18 CV 2069

Judge Sarah Ellis

Magistrate Judge Maria Valdez

PLAINTIFF’S OBJECTIONS AND ANSWERS
TO DEFENDANTS’ FIRST SET OF INTERROGATORIES
Plaintiff, Alaina Hampton (“Plaintiff”), by and through her attorneys, for her objections
and answers to Defendants’ First Set of Interrogatories, pursuant to Rule 33(b) of the Federal Rules
of Civil Procedure, hereby states as follows:
Preliminary Statement
With respect to each answer set forth herein, Plaintiff’s investigation continues and
Plaintiff reserves the right to supplement and/or amend any answer as necessary and as additional
information is obtained through discovery or otherwise.
General Objections
1.

Plaintiff objects to each and every Interrogatory, and to Defendants’ “Definitions”

and “Instructions,” to the extent they purport to impose obligations on Plaintiff greater than those
contemplated by the Federal Rules of Civil Procedure and the Local Rules of the Northern District
of Illinois.

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2.

Plaintiff objects to Defendants’ Interrogatories to the extent they call for

confidential information or for information protected by the attorney-client privilege or work
product doctrine.
3.

Plaintiff’s investigation is ongoing. Plaintiff reserves the right to supplement these

answers in light of her ongoing investigation.
ANSWERS TO INTERROGATORIES
1.

Identify each charge, lawsuit or claim (other than this lawsuit) you have ever filed,

brought (individually or jointly) or been a party to, including but not limited to, any suits filed
against former employers or entities to whom you provided services under contract or agreement.
With regard to each such charge, lawsuit or claim, provide the name of the court or forum, the
complete case title and case or docket number, the names of the parties to the litigation or claim, a
brief description of the nature of the matter, and a brief summary of the final disposition of the
matter.
ANSWER:

Plaintiff objects to this Interrogatory on the ground that it is overbroad

as it seeks information that is not relevant to any claims or defenses in this case such that the
burden of producing the requesting information is outweighed by its value, if any, to the case.
Subject to and without waiving the foregoing objection, Plaintiff answers none.
2.

For the time period 2012 to the present, identify in chronological order, each

position, job or contracted project you have held or been engaged for and for each position, job or
contracted project identified, provide the name and address of the employer or contracting entity,
the dates/time period of employment or engagement, job title or position (if applicable), duties and
responsibilities, compensation received from such employment or engagement, the name of any

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supervisor or other individual to whom you reported and the reason(s) for separation or termination
of such employment or engagement.
ANSWER:

Plaintiff objects to this Interrogatory on the grounds that it is overly

broad in both scope and time. Subject to the foregoing objection, Plaintiff answers, to the
best of her recollection, as follows:
Longhorn Steakhouse: June 2008 – Feb.2013 (on and off)
Springfield, Illinois
Waitress
Direct Supervisor: Unknown
Compensation: approx. $4 per hour plus tips
Reason for separation: moved to Chicago to work for Speaker Madigan.
DPI/Democratic Majority: August- Sep. 2012
Field Organizer for State Representative Elect Sue Scherer
Supervisor: Kristin Bauer
Compensation: see Plaintiff’s document production
Reason for separation: end of election cycle
DPI/Democratic Majority: Oct. 2012 – mid-Nov. 2012
Field Organizer for State Representative Elect Kathleen Willis
Direct Supervisor: Lisbeth Ramirez
Regional Supervisor: 13th Ward Alderman Marty Quinn
Compensation: see Plaintiff’s document production
Reason for separation: end of election cycle
Ill. House of Reps., Office of the Speaker: March 2013 – Feb. 2014; March– June 2014
21st Illinois House Representative District (Representative Silvana Tabares)
Chicago, Illinois
Program Specialist
Supervisor: 13th Ward Alderman Marty Quinn
Compensation: $31k per year
Reason for separation: to work on State Representative Candidate Sam Rosenberg’s election
DPI/Democratic Majority/Friends of Madigan/Sam Rosenberg for State Rep: Feb.–March
2014
Champaign, Illinois
Campaign Manager for State Representative Candidate Sam Rosenberg
Supervisor: Shaw Decremer
Compensation: see Plaintiff’s document production
Reason for separation: end of election cycle

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The Greenbay Café: Nov. 2014 – 2017 (on and off)
Server
Supervisor: Carla (LNU)
Compensation: approx. $4 per hour plus tips
DPI/Deb Mell for 33rd Ward Alderman: Dec. 2014 – March 2015
Campaign Manager
Supervisor: Shaw Decremer
Compensation: $10k
Reason for separation: end of election cycle
Waterhouse Tavern & Grill: April 2015 –present (on and off)
Chicago, Illinois
Server/bartender
Supervisor: Brian Myers
Compensation: approx. $5 per hour plus tips
Bruno’s Restaurant: August –Nov. 2015
Denver, Colorado
Server
Supervisor: Nick (LNU)
Compensation: approx. $4 per hour plus tips
Reason for separation: moved back to Chicago to work on Juliana Stratton’s campaign
Fooducopia: Aug. – Nov. 2015
Denver, Colorado
Server
Supervisor: Tim (LNU)
Compensation: approx. $5 per hour plus tips
Reason for separation: moved back to Chicago to work on Juliana Stratton’s campaign
Friends of Juliana Stratton/DPI: Dec. 2015–March 2016
Chicago, Illinois
Campaign Manager
Supervisor: Alderman Marty Quinn
Compensation: $2900 per month
Reason for separation: end of election cycle
Chicago Heights Economic Development Corp.: July-Oct. 2016; mid-Nov.-April 2017
Chicago Heights, Illinois
Program Coordinator
Direct Supervisor: Jack Hynes
Compensation: $51k per year
Reason for separation: leave of absence to work on Deb Conroy’s campaign (Oct. 2016) and
subsequently she resigned (April 2017)

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DPI/Democratic Majority/13th Ward Democratic Org. /Friends of Madigan: June- Nov. 2016
Chicago, Illinois
Field Organizer for Marwig and Cloonen campaigns
Supervisors: 13th Ward Alderman Marty Quinn and Kevin Quinn
Compensation: $200 per day
Reason for separation: end of campaign cycle
DPI/Democratic Majority/13th Ward Democratic Org. /Friends of Madigan: Oct.-Nov. 2016
Chicago, Illinois
Campaign Advisor for Deb Conroy
Direct Supervisor: 13th Ward Alderman Marty Quinn
Compensation: see Plaintiff’s document production
Reason for separation: end of campaign cycle
Steger Municipal Election: March – June 2017
Chicago, Illinois
Campaign Manger
Direct Supervisor: David Gonzales
Compensation: $2000
Reason for separation: end of election
Marie Newman for Congress: April – Aug. 2017
Chicago, Illinois
Campaign Manager
Direct Supervisor: Marie Newman
Compensation: $7500 per month
Reason for separation: resignation
Friends of Christian Mitchell: Sep. 2017-Jan. 2018
Chicago, Illinois
Field Director for petition process
Direct Supervisor: Christian Mitchell
Compensation: $2000 per month
Reason for separation: petition process ended
Hampton Moore LLC: Oct. 2017 – 2018
Chicago, Illinois
Co-Founder
Fundraising and political consulting firm for various clients including:
• Oran F. Whiting for Judge: Nov. 2017
• Friends of Holly Kim: Nov. 2017- Jan. 2018
• Friends of Curtis Tarver: Sep. 2017 – Feb. 2018
• Friends of Bridget Degnen: Nov. 2017- March 2018
• Elect Judge Mackoff: Feb. 2018
Compensation: see Plaintiff’s document production.

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Dan McCready for Congress/North Carolina Democratic Party: Sept. 2018- present
Charlotte, North Carolina
Campaign Manager
Supervisor: Eric Johnson
Compensation: $6000 per month
3.

For each individual or entity with whom you have applied or sought employment

or engagement at any time since January 1, 2017, identify he name of the individual or entity with
whom you sought employment or an engagement, the date you applied or sought engagement, the
position(s) or job(s) for which you applied, and whether you were offered employment or
engagement, and, if not, the reason(s) given and by whom.
ANSWER:

Plaintiff incorporates her answer to Interrogatory No. 2 herein as if

stated in full. Answering further, Plaintiff states, to the best of her recollection, that, between
January 1, 2017 and the present, she formally or informally sought employment with the
following individuals and/or entities:
Chicago Teacher’s Union (CTU):
In or around September 2017, Plaintiff had conversations with D’Javan Conway, a contract
lobbyist for CTU, about CTU retaining Plaintiff to work on Johane Strong’s Fifth District
statement representative campaign. In or around October 2017, Plaintiff had a meeting with
Stacy Davis Gates, CTU’s political director, Emma Tai of United Working Families and
Johane Strong to discuss retaining Plaintiff to assist with the campaign. After the meeting,
Plaintiff was led to believe that CTU wanted to work with her and that CTU was in the
process of finalizing the employment offer. Approximately one week later, while in
Springfield, D’Javan Conway reached out to Plaintiff and asked to meet with her. At the
meeting, D’Javan Conway asked Plaintiff if she was “on the outs” with Alderman Marty
Quinn as someone had informed Stacey Davis Gates that such was the case. Plaintiff never
heard back from CTU, Stacey Davis Gates, Emma Tai and/or Johane Strong after the
meeting with D’Javan Conway.
Kristin Crowell Campaign:
Beginning in or around October 2017, Plaintiff had conversations with Kristin Crowell about
working with her on her upcoming campaign when she was planning on running for state
representative. After numerous conversations in which Plaintiff was led to believe that
Crowell was interested in working with Plaintiff, Plaintiff never heard back. In or around
April, 2018, Plaintiff learned from Emily Miller that Crowell had been told not to work with
Plaintiff.

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Kwame Raoul Campaign for Attorney General
In or around October 2017, Plaintiff was offered employment as Deputy Campaign Manager
for Kwame Raoul’s campaign. Plaintiff was unable to accept the employment offer as she
had already committed to working with Curtis Traver’s and was also hoping to be hired by
Defendants to work on the Fifth District race.
Fifth District Campaign:
In or around November 2017, Plaintiff indicated her desire to work for Defendants and
inquired of Heather Weir Vaught about a job opportunity on the then upcoming Fifth
District race. Vaught informed Plaintiff that she would set up a meeting between Plaintiff
and Alderman Marty Quinn to discuss the job opportunity. Vaught, however, never
followed up with Plaintiff. As such, in or around January 2018, Plaintiff contacted Vaught
and again inquired about employment with Defendants to work on the Fifth District race.
In response, Vaught stated that Defendants would not being getting involved in the Fifth
District race and therefore no job opportunity would be available to Plaintiff. Plaintiff
learned that Vaught’s statement was false and that Defendants were in fact getting involved
in the race and hired someone else to work on the Fifth District campaign.
English First
In December, 2017, Plaintiff accepted a position with English First in China. Plaintiff
deferred the opportunity and then ultimately had to decline it.
Anti-Harassment, Equality and Access (AHEA) Panel
In or around March 2018 Plaintiff submitted an online application for the panel coordinator
position for the AHEA Panel. On or about June 19, 2018, Plaintiff was notified via email
that the AHEA Panel had decided to hire another candidate.
Ayanna Pressley Congressional Campaign (Boston, Massachusetts)
In or around April 2018, Plaintiff applied to be the campaign manager for Ayanna Pressley’s
campaign. Plaintiff interviewed for the position but then never heard back.
Deb Mell Campaign
In or around July 2018, Alderman Mell contacted Plaintiff about employing Plaintiff as her
campaign manager. On or about August 6, 2018, Plaintiff met with Alderman Mell to
further discuss the job opportunity. During the meeting, Alderman Mell expressed concerns
about working with Plaintiff in light of Plaintiff’s pending lawsuit against Defendants.
Alderman Mell indicated that she was worried that the Defendants would retaliate against
her if she hired Plaintiff. Plaintiff never heard back from Alderman Mell after the August
6, 2018 meeting.
Democratic Party of Illinois
On or about July 11, 2018, Plaintiff submitted her resume in consideration for the Executive
Director position with the Democratic Party of Illinois. Plaintiff never heard back but
learned that the position went to someone else.

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UltraViolet
On or about August 10, 2018, Plaintiff applied for the position of associate campaign
director. On or about August 15, 2018, Plaintiff was notified by Holly Witherington that she
did not get the position and that they were moving forward with a different applicant.
Other Potential Employment Opportunities
In 2018, Hampton Moore LLC sent proposals to various individuals, including Alderman
John Arena, Alderman Scott Waguespack, and Alderman Candidate Erika Wozniak, for
consulting work. However, neither Plaintiff nor Hampton Moore LLC were engaged to
provide consulting services.
Plaintiff’s investigation continues.
4.

For the time period January 1, 2016 to the present, identify each job or contracted

project Hampton Moore LLC has been engaged for and for each job or contracted project
identified, provide the name and address of the client or contracting individual/entity, the
dates/time period of engagement, the nature of the job, project or engagement, and the income
received for each job, project or engagement.
ANSWER:

Plaintiff objects to this Interrogatory to the extent it seeks confidential,

sensitive and private information about individuals and/or entities who are not parties to the
case. Plaintiff also objects on the grounds that it seeks certain information, i.e. the address of
the client or contracting individual/entity that is not relevant to any issue in the case. Subject
to and without waiving the foregoing objections, Plaintiff answers, to the best of her
recollection, that Hampton Moore LLC was engaged as follows:
Friends of Curtis Tarver: Sep. 2017 – Feb. 2018
Chicago, Illinois
Nature of Engagement: Consulting
Compensation: $7500
Oran F. Whiting for Judge: Nov. 2017
Chicago, Illinois
Nature of Engagement: Fundraising Consulting
Compensation: $2500

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Friends of Holly Kim: Nov. 2017- Jan. 2018
Mundelein, Illinois
Nature of Engagement: Consulting/Campaign Work
Compensation: $2000
Friends of Bridget Degnen: Nov. 2017- March 2018
Chicago, Illinois
Nature of Engagement: Consulting
Compensation: $16,130.75
Elect Judge Mackoff: Feb. 2018
Chicago, Illinois
Nature of Engagement: Consulting
Compensation: $1500
Plaintiff’s investigation continues.
5.

Identify each individual whom you contend to be an agent or representative of any

of the Defendant committees who you allege retaliated against you as alleged in the Amended
Complaint. For each person identified, provide the date on which such alleged retaliation occurred,
a brief description of the conduct alleged to be retaliatory and whether you have any documents
supporting or reflecting the information provided in response to this Interrogatory.
ANSWER:

Plaintiff objects to this Interrogatory as it calls for a legal conclusion as

to whether an individual is an “agent or representative” of the Defendant-committees, and
calls for information protected by the work-product doctrine. Plaintiff also objects to this
Interrogatory to the extent it seeks information that is within Defendants’ possession and
control and/or information that Defendants have not yet produced in discovery. At this point
in the case, Plaintiff does not have knowledge of every individual who was involved in the
alleged discriminatory/retaliatory conduct and/or the decision-making process. Plaintiff also
objects to this Interrogatory on the ground that it calls for a narrative response better suited
for an oral discovery deposition.

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Subject to and without waiving the foregoing objections, based on the information
currently available to Plaintiff, and by way of summary only, Plaintiff answers as follows:
Individuals Involved: The following individuals were involved in the unlawful and/or
retaliatory conduct alleged in the Complaint: Alderman Marty Quinn, Speaker Michael J.
Madigan, Heather Weir Vaught and other agents and/or representatives of the Defendantcommittees unknown to Plaintiff as this time.
Summary of Retaliation: Between 2012 and 2017, Plaintiff worked successfully as a
political staffer and campaign manager for the Defendant-committees controlled by Speaker
Madigan. From Approximately July 2016 through December 2016, Defendants assigned
Plaintiff to work on three separate campaigns. Beginning in or around August, 2016, and
through February 2017, one of Plaintiff’s supervisors, Kevin Quinn, subjected Plaintiff to
severe and pervasive sexual harassment by pursing Plaintiff to have a romantic and sexual
relationship with him.
In approximately mid-February 2017, Plaintiff reported Kevin Quinn’s sexual
advances and harassment to her and Kevin Quinn’s supervisor, Alderman Marty Quinn.
Alderman Quinn, however, failed to take sufficient corrective or remedial action. Instead,
Alderman Quinn informed Plaintiff that she could “block” Kevin Quinn’s phone number
and that she would no longer be required to report to Kevin Quinn directly. Despite this,
however, Alderman Quinn indicated that he wanted Plaintiff’s next assignment within the
Defendants’ organizations to be working as a 13th Ward precinct officer which, however,
would require Plaintiff to again work with Kevin Quinn. As a result of Defendants’ failure
to properly address and rectify the situation, Plaintiff was forced to stop working for
Defendants and was constructively discharged.

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In November 2017, Plaintiff again reported the sexual harassment/hostile work
environment, this time directly to Speaker Madigan. Specifically, on or about November 1,
2017, Plaintiff wrote a letter to Speaker Madigan to explain the circumstances surrounding
her departure as she did not believe, based on her conversation with Speaker Madigan on or
about April 17, 2017, at a political fundraiser that Plaintiff hosted for Juliana Stratton, that
Alderman Quinn had informed Speaker Madigan of what had transpired. Plaintiff contacted
Speaker Madigan with the expectation that, once informed of the true circumstances of why
she stopped working for the Defendants, Speaker Madigan would allow her to return to work
for Defendants on the upcoming Fifth District race in her former role.
Speaker Madigan did not respond to Plaintiff’s letter. Instead, on or about November
13, 2017, Defendants’ private attorney, Heather Weir Vaught, called Plaintiff and scheduled
a meeting with her for November 15, 2017. At the meeting, Plaintiff provided Vaught with
hard copies of all of the sexually harassing text messages she received from Kevin Quinn and
asked Vaught to share them with Speaker Madigan. Plaintiff also asked Vaught about being
hired by the Defendants to work on the upcoming Fifth District campaign as she had done
so previously for Juliana Stratton. While Vaught minimized Kevin Quinn’s sexual
harassment and told Plaintiff she was not sexually harassed or subjected to a sexually hostile
work-environment because Plaintiff was not technically an “employee”, Vaught promised to
arrange for a meeting between Plaintiff and Alderman Quinn to discuss the possibility of
Plaintiff working for the Defendants on the upcoming Fifth District race.
On or about December 12, 2017, Plaintiff sent Vaught a text message asking if it was
okay if she contact Alderman Quinn directly to discuss assisting him on the Fifth District
race, as Vaught had not followed up with Plaintiff as promised during their November 15th

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meeting. In response, Vaught told Plaintiff she would call her the next day to discuss it
further but she never did.
On or about January 15, 2018, Plaintiff again reached out to Vaught via text message.
Vaught responded stating that she would contact Plaintiff later that day but never did.
Having not heard back from Vaught, later that day, Plaintiff contacted Alderman Quinn
directly regarding opportunities to work for Defendants on upcoming campaigns. Alderman
Quinn did not respond. Instead, almost immediately after sending the email, Vaught called
Plaintiff and told her that the Defendants would not be hiring her to work on the Fifth
District campaign because the Defendants would not be getting involved in that race.
This, however, was untrue as Defendants ultimately hired another individual to work
on the Fifth District campaign. Defendants and their agents and representatives, including
Speaker Madigan, Alderman Quinn, Heather Weir Vaught and other individuals unknown
to Plaintiff at this time, refused to hire Plaintiff to work on the Fifth District race, a job for
which she was undeniably qualified for, in retaliation for her reporting Kevin Quinn’s sexual
harassment and the sexually hostile work environment that she was forced to endure. The
stated reasons for Defendants’ failure to hire Plaintiff to work on the Fifth District race were
pretexts to hide their unlawful employment actions.
Indeed, between February 2017, and February 2018, despite Plaintiff’s reports to
Speaker Madigan, the Defendants, and Alderman Quinn, Kevin Quinn continued to work in
a supervisory capacity for the Defendants. At no time between November 2017, when Vaught
first contacted Plaintiff on behalf of the Defendants, and February 2018, when the
Defendants terminated Kevin Quinn, did Vaught or the Defendants inform Plaintiff that they
were conducting an investigation into her allegations of sexual harassment against Kevin

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Quinn. Defendants only terminated Kevin Quinn when they learned that Plaintiff was going
public with her allegations.
Additionally, based on information and belief, Defendants retaliated against Plaintiff
for reporting and/or complaining of the sexual harassment identified in the Complaint in
that they interfered and precluded Plaintiff from obtaining employment with the Chicago
Teacher’s Union, Kristen Crowell and other individuals and/or entities.
Plaintiff directs Defendants to the documents attached to the Amended Complaint.
Answering further, Plaintiff will produce any non-privileged documents in her possession
that are responsive to this request. Plaintiff’s investigation continues.
6.

State each and every fact relating to or supporting your claim that you were

constructive (sic) discharged as alleged in Paragraph 36 of the Complaint, and identify any
documents reflecting the information provided in response to this Interrogatory.
ANSWER:

Plaintiff objects to this Interrogatory as it calls for a legal conclusion as

to whether she was “constructively discharged” and information protected by the workproduct doctrine. Plaintiff also objects to this Interrogatory to the extent it seeks information
that Defendants have not yet produced in discovery. Plaintiff also objects to this
Interrogatory on the ground that it calls for a narrative response better suited for an oral
discovery deposition.
Subject to and without waiving the foregoing objections, Plaintiff states that she was
constructively discharged by Defendants as a result of Defendants’ failure and/or refusal to
take corrective or remedial action after Plaintiff, in February 2017, first reported the sexual
harassment/sexually hostile work environment. In fact, Alderman Quinn told Plaintiff that
her next assignment within the Defendants’ organization would be to work as a precinct

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captain which would have required Plaintiff to again work directly with Kevin Quinn, the
very supervisor who was sexually harassing Plaintiff. As a result of the Defendants’ failure
to remedy the situation or take appropriate action, in April, 2017, Plaintiff was forced to stop
working for the Defendants because she could no longer suffer the crippling fear and anxiety
she experienced having to work with Kevin Quinn.
The Defendants again failed to take corrective or remedial action after Plaintiff
directly informed Speaker Madigan of the sexual harassment/hostile work environment
identified in the Complaint. Indeed, between February 2017, and February 2018, despite
Plaintiff’s reports to Speaker Madigan, the Defendants, and Alderman Quinn, Kevin Quinn
continued to work in a supervisory capacity for the Defendants. At no time between
November 2017, when Vaught first contacted Plaintiff on behalf of the Defendants, and
February 2018, when the Defendants terminated Kevin Quinn, did Vaught or the Defendants
inform Plaintiff that they were conducting an investigation into her allegations of sexual
harassment against Kevin Quinn. Defendants only terminated Kevin Quinn when they
learned that Plaintiff was going public with her allegations.
Plaintiff directs Defendants to the documents attached to the Amended Complaint
filed in this matter. Answering further, Plaintiff will produce any non-privileged documents
in her possession that are responsive to this request. Plaintiff’s investigation continues.
7.

Do you claim emotional and/or psychological damages as part of your claim? If

so, identify the name and contact information for each doctor, psychologist, hospital, clinic,
counselor, association, or other professional or medical facility or entity at which or by whom
Plaintiff has been or is being treated, counseled, diagnosed, examined, or otherwise provided

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assistance for any physical or emotional injury or condition within the relevant time period, the
date and/or period of time of such treatment, and a brief description of the nature of such treatment.
ANSWER:

Except for health care treatment regarding emotional distress caused

by Defendants, Plaintiff objects to this Interrogatory on the grounds that it requests
information that is private, confidential and irrelevant for the purposes of this case. Plaintiff
further objects to this Interrogatory as it seeks information protected by the doctor-patient
privilege. Plaintiff also objects on the grounds that it is overbroad, unduly burdensome and
seeks information beyond any reasonable time frame calculated to elicit relevant evidence.
As such, the burden of answering this Interrogatory far outweighs any likely benefit and
would be disproportionate to the needs of this case.
Without waiving the foregoing objections, Plaintiff answers yes and states, between
January 1, 2016 and the present, she received mental health treatment as a result of
Defendants’ conduct from the following individuals and/or entities:
Carmen Juneidi
Lifespan
70 E. Lake Street, Suite 700
Chicago, Illinois 60601
Began treatment in April 2018
Dr. Peter Newman
405 N Wabash Ave Unit 1814
Chicago, IL 60611
Sought Treatment in August, 2018
Plaintiff’s investigation continues.
8.

State each and every fact relating to or supporting your claim alleged in Paragraph

51 of the Complaint that “[Defendants] have ignored and/or disregarded other reports of sexual
harassment of female employees and volunteers working for the [Defendants]” and identify any
documents reflecting the information provided in response to this Interrogatory.
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ANSWER:

Plaintiff objects to this Interrogatory on the grounds that it calls for a

narrative response better suited for an oral discovery deposition. Plaintiff also objects on the
grounds that it does not clearly, certainly or specifically identify what information is being
sought as it seeks “every fact relating to or supporting” the allegation, which is vague, overly
broad, ambiguous, and would require Plaintiff to speculate about the intended meaning of
the request.

Plaintiff also objects to this Interrogatory on the ground that it seeks

information and/or documents that is already in Defendants’ possession, custody and control
and information Defendants have not yet produced in discovery.
Subject to and without waiving the foregoing objections, Plaintiff states, by way of
summary only, that she came to learn that other females employed by the Speaker had been
sexually harassed and/or assaulted by a male co-worker, Travis Shea. Both females reported
Travis Shea’s sexual harassment and/or assault directly to attorney Heather Weir Vaught but
nothing was done in response. In fact, Mr. Shea remained on the Speaker’s staff for an
additional two years thereafter. Plaintiff’s investigation continues.
9.

Identify all internet social media and networking websites analog or digital

photograph, still image or video sharing websites, and web logs (blogs), internet message boards,
chat rooms, or public forums that you have used, posted on, or maintained an account since January
1, 2012. “Internet social media and networking websites” includes but is not limited to Facebook,
Facebook Messenger, Twitter, LinkedIn, Instagram, XboxLive, Foursquare, Instagram, Whatsapp,
Windows Live Spaces, Pinterest, Google+, Google Hangouts, Tumblr, Flickr, Skype, FaceTime,
Snapchat, Reddit, ASKfm and Meetup.
ANSWER:

Plaintiff objects to this Interrogatory on the ground that it seeks

irrelevant information as Plaintiff’s social media accounts are only relevant if she used them

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to post information related to this case. Plaintiff further objects on the grounds that it
requests information that invades Plaintiff’s privacy. Subject to and without waiving the
foregoing objections, Plaintiff has used the following social media accounts between January
1, 2012 and the present: Facebook, Twitter, Instagram, Snapchat, LinkedIn, Pinterest,
Skype, and FaceTime.
10.

With respect to all internet social media and networking websites, analog or digital

photograph, still image or video sharing websites, and web log (blog), internet message board, chat
room, or public forums identified in your answer above, provide your current user name, screen
name and password. Alternatively, provide a copy of all non-privileged content/data shared on
each account that relates to the claims, allegations or defenses in the Amended Complaint.
ANSWER:

Plaintiff will produce copies of all non-privileged content/data shared

on each account that relates to the claims, allegations or defenses in the Amended Complaint.
Plaintiff’s investigation continues.
11.

Provide email addresses of any email account(s) and phone numbers that you have

used or maintained since January 1, 2014.
ANSWER:
Email Accounts:

Ahampton789@gmail.com; alaina@hamptonmoore.com

Cell Phone:

217.891.5717

12.

For every account identified in Interrogatory 8 above, describe in detail any and all

content you have deleted, erased or changed status from visible to non-visible on or after January
1, 2017, including but not limited to tweets, blog entries, photographs, videos, chats, messages,
posts, name/username changes to any accounts and the deletion of any accounts.

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ANSWER:

To the best of Plaintiff’s recollection, she did not delete or erase any

posts, tweets etc., however, Plaintiff believes that she did make one Facebook post non-visible,
but states that said post will be produced to Defendants in discovery. Plaintiff’s investigation
continues.
13.

Identify every personal trip/vacation taken by you since August 1, 2012 through the

present and identify date(s)/length of travel identified, location(s) of travel, reason(s) for travel,
and whether any documents exist reflecting the information provided in response to this
Interrogatory, including its subparts.
ANSWER:

Plaintiff objects to this Interrogatory on the ground that is seeks

information with no probative value to any disputed factual or legal issue in this case.
Accordingly, it follows that the burden of answering this Interrogatory outweighs any likely
benefit and would be disproportionate to the needs of this case. In light of the foregoing,
Plaintiff declines to answer this Interrogatory.
14.

Identify each item of damages you are seeking in this matter and, for each, state the

nature of the damages, the amount of the damages; and whether any documents exist reflecting or
supporting the information provided in response to this Interrogatory.
ANSWER:

Based on information currently available, Plaintiff is seeking damages

as follows:
Statutory Compensatory Damages: Pursuant to Title VII, Plaintiff reasonably believes she
is entitled to statutory compensatory damages in the amount of $300,000 (based on the
reasonable belief that Defendants’ total number of employees, including volunteers, exceeds
500). Documents support his belief are exclusively within Defendants’ possession and/or
control.
Actual Damages: Plaintiff seeks actual damages, in the form of lost wages, in the amount of
approximately $1272.95. This amount is calculated using information from public filings as
to the salary paid to Laura Duszynski for her work on the 5th District Race minus monies
Plaintiff received during that same time period, i.e., January 31, 2018 through March 30,
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 Case: 1:18-cv-02069 Document #: 45-2 Filed: 03/01/19 Page 19 of 22 PageID #:486

2018. Plaintiff seeks additional damages for the emotional harm suffered, including mental
anguish, inconvenience and loss of enjoyment of normal life activities, as result of
Defendants’ misconduct, the exact amount to be determined at trial. Documents supporting
Plaintiff’s actual damages are within Defendants’ possession and/or control, and/or in the
possession of third parties, such as Laura Duszynski. Other documents supporting Plaintiff’s
damages, including medical bills, to the extent available, will be identified and produced.
Equitable Relief: Plaintiff also seeks equitable relief in the form of front pay, in an amount
to be calculated based on the date of the verdict and/or reinstatement to a comparable
position.
Punitive Damages: Plaintiff seeks punitive damages sufficient to deter and punish the
Defendants for their discriminatory/retaliatory misconduct in an amount to be determined
by the jury at trial.
Reasonable Attorneys’ Fees, Costs and Litigation Expenses: amount to be determined at the
conclusion of litigation.
Pre/Post-Litigation Interest: to be determined at trial.
Plaintiff’s investigation continues.
15.

Identify any and all financial support you have received (or have been promised to

receive) from any source whatsoever from January 1, 2017 to the present, including but not limited
to litigation funding, and the amount of financial support provided from each source identified.
ANSWER:
16.

None.

Identify all witnesses whom you will or may call as experts to give opinion

testimony in the trial of this matter. For each witness identified, state the substance of the opinions
to which he/she is expected to testify and identify any documents containing or relating to his/her
conclusions and opinions and considered, used or relied upon by the expert in forming his or her
conclusions or opinions or in investigating or considering the matters relating to which he or she
was retained.
ANSWER:

Plaintiff objects to this Interrogatory to the extent that it seeks

information beyond what is required by Rule 26. Subject to and without waiving this

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 Case: 1:18-cv-02069 Document #: 45-2 Filed: 03/01/19 Page 20 of 22 PageID #:487

objection, Plaintiff states that she has not yet determined who will be called at trial in this
matter but retains the right to disclose such information within the time prescribed by the
Court and the Federal Rules. Plaintiff’s investigation continues
17.

Identify all verbal, written or other statement (s) Plaintiff (or any agent acting on

Plaintiff's behalf) has obtained which in any way relates to the claims or defenses in this case.
ANSWER:

Plaintiff does not currently possess any written statements related to

this case, but if and when she does come into possession of such statements and produces
them, that production will serve as the answer to this Interrogatory pursuant to Fed. R. Civ.
P. 33(d). As to verbal statements, Plaintiff identifies an audio recording of a telephone
conversation between Kevin Quinn and Sarah McKay that took place on February 9, 2018
at approximately 2:45 pm. Plaintiff’s investigation continues.

Date: October 12, 2018

Respectfully submitted,
KULWIN, MASCIOPINTO & KULWIN, LLP
/s/ Rachel A. Katz
One of Plaintiff’s Attorneys

Shelly B. Kulwin
Jeffrey R. Kulwin
Rachel A. Katz
KULWIN, MASCIOPINTO & KULWIN, LLP
161 N. Clark Street, Suite 2500
Chicago, Illinois 60601
(o): 312.641.0300; (f): 312.855.0350
skulwin@kmklawllp.com
jkulwin@kmklawllp.com
rkatz@kmklawllp.com

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 Case: Document 45-2 Filed: 03/01/19 Page 21 of 22 PageID #:488

VERIFICATION
I, Alaina Hampton declare under penalty of perjury that the foregoing Answers to

Defendants? First Set 0fInterrogat0ries are, to the best of my information and belief, true and
correct. -

Executed this A day of October, 2018. MW
A .

laina Hampton

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Case: 1:18-cv-02069 Document #: 45-2 Filed: 03/01/19 Page 22 of 22 PageID #:489

CERTIFICATE OF SERVICE
I, Rachel A. Katz, an attorney, state that I served the instant and foregoing Plaintiff’s
Objections and Answers to Defendants’ First Set of Interrogatories by electronic mail to the
attorneys of record below on October 12, 2018.
/s/ Rachel A. Katz

Aimee Delaney
James M. Lydon
HINSHAW & CULBERTSON LLP
151 N. Franklin St., Suite 2500
Chicago, Illinois 60606
Telephone: 312-704-3000
Facsimile: 312-704-3001
adelaney@hinshawlaw.com
jlydon@hinshawlaw.com

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