GLENDA NEEDS HELP! She is defending herself pro se which means alone against UND Associate Physics Professor John L Wagner and his two attorneys, so we request help on questions Glenda can ask him in court. Responses may be posted on http://www.und-fraud.com/Discussion2/index.html
Here is what has been submitted so far:
Interrogatories (Set 1)
Interrogatory No.1: For each person providing information in response to these Interrogatories, state your full name, birth date, place of birth, Social Security Number and any other names by which you have ever been known. Please provide the names, addresses, and current phone numbers of your parents, your two brothers, and your brother’s ex-wife. Please provide also the name of your brother’s young daughter with the heart condition that caused her to be hospitalized during her first year of life.
Interrogatory No.2: For each person providing information in response to these Interrogatories, state your present address and the addresses of each place you have ever lived with the dates you lived at each address. Please include also the full name of your college roommate Charlie and his current address and phone number.
Interrogatory No. 3: For each person providing information in response to these Interrogatories, provide in detail the names, addresses and phone numbers of every woman or man you have ever dated, how long each of these relationships lasted and provide in detail why each relationship broke up. Please include and identify the woman attorney you said hit you in the mouth, the medium, the woman who gave you a copy of the book Peter Pan Syndrome, the blind date who said that she went back to her boyfriend and asked that you never call upon her again, and the woman that you said shakes when you enter a room and she sees you at UND. Please explain your statement that you have never dated a woman for more than six months and are not on speaking terms with anyone that you have ever dated.
Interrogatory No. 4: For each person providing information in response to these Interrogatories, if you have pleaded guilty or have been convicted of any crime, for each such crime please state the date, nature of offense, and court involved, and whether you have ever been involved in any settlement of a criminal matter. Please include all speeding tickets and reported traffic accidents.
Interrogatory No. 5: For each person providing information in response to these Interrogatories, have you ever been involved in any other legal action as a party or witness? If so, state the names of each party involved, the date and place of the legal; action or claim, and please state whether you have ever been involved in any settlement of a criminal matter.
Interrogatory No. 6: Describe your entire employment history in chronological order, including present employment, by stating the name and address of each employer, dates of each employment, type of work, job title, supervisor, number of hours worked per week, wage or salary received, and reason for termination of or leaving from each position.
Interrogatory No. 7: With respect to each of the past twenty full calendar years (before this year), state your yearly gross income and attach photocopies of your tax returns. If you are or were not employed, please state the amount and source of all income received. Please include any grants, loans or gifts you have received.
Interrogatory No. 8: State the name and address of each person whom you expect to call as an expert witness at the trial. For each such person named, state:
a. The background, training, experience and qualifications of the expert;
b. The subject matter upon which the witness is expected to testify, the facts and opinions to which the expert is expected to testify, and a summary of the ground for each opinion;
Whether the expert has been a witness in any other lawsuit, and, if so, the names of the parties of such actions, the jurisdiction and venue, civil or file number, date of court appearances, and disposition made; and
Attach a current curriculum vitae and bibliography for the expert.
Interrogatory No. 9: State with regard to each and every person whom you expect to call as witness (but not as an expert witness) at the trial of this matter:
His/ her identity;
The nature of his/her testimony; and
Whether his/her testimony will be presented by means of a deposition.
Interrogatory No. 10: Do you masturbate? If not, do you have nocturnal emissions? If you do, are the subjects of your fantasies men, women, elderly women or prepubescent children? Do you subscribe to any pornographic materials on the Internet or any hard copy pornographic materials? Please state in detail and not in summary fashion all fantasies that you find sexually arousing. When you masturbate how long does it take for you to reach ejaculation? Have you ever masturbated until you were just ready to ejaculate and phoned your students to "talk"?
Interrogatory No. 11: Do you participate in phone sex? How often do you participate in sex via telephonic means? Have you ever offered a student a reward such as a grade change in exchange for phone sex? Have you ever changed a grade for such activity? Have you ever changed the grade of a student? Please state in detail and not in summary fashion all facts supporting your claim during the disciplinary hearing at the University of North Dakota in which you stated that you changed Miskin’s grade from a "d" to a "b" to satisfy her demands for payment as such and that you (Wagner) then raised the grades of all other students to be "fair."
Interrogatory No. 12: Please describe the layout of the apartment that you resided in during the 1998 year. Were there stairs that caused you to be out of breath when you phoned your students? If so, how steep were these stairs? Please state the name, address, and phone number of the apartment manager at your previous residence. Please state in detail and not in summary fashion all facts supporting your claim that there were steep stairs that made you breath heavily before you phoned Miskin from your home to hers in the late evenings for an hour and a half or more on as many as twenty occasions.
Interrogatory No. 13: Please provide the names, addresses, and current phone numbers of any graduate teaching students you had that were from Africa. Did he speak several languages? Did people stare at him? Did you stare at him? What parts of his body did you stare at?
Interrogatory No. 14: Do you participate or have you participated in youth groups as a teacher or leader? Are you, or have you ever been a Boy Scout Leader?
Interrogatory No. 15:What church do you belong to? Please state the name and current address of your minister. Do you participate or have you participated in youth groups as a teacher or leader? Do you share your sexual fantasies with church members?
Interrogatory No. 16: Please identify any and all documents, photographs, and videotapes reviewed by you for purposes of responding to the foregoing Interrogatories.
Interrogatory No. 17: Identify any person(s) known to you who possesses, or claims to possess, knowledge of any fact or document relating to the allegations set forth by either party to this matter.
Interrogatory No. 18: Have you obtained any statements from any person(s) regarding the present matter? If so, for each statement: identify the person to whom it was made; all persons presently having custody of it; whether it was written and signed or otherwise adopted or approved by the person; and whether it was verbal and recorded or transcribed.
Interrogatory No. 19: State whether you know of any other tangible things containing evidence related to this action not previously listed herein. If so, with respect to each state:
Its nature and specific subject matter;
The date the same was made or taken;
The identity of the person making or taking the same; and
The identity of the person in whose possession the same now is.
Interrogatory No. 20: Please state whether you have ever received any mental health care, the nature of such care, the location/providers of such care, the date of such care, and whether that care is ongoing as present.
Interrogatory No. 21: Please provide the name, address and phone number of the heart specialist who treated you after you swooned during class in Fall 1998. Was your personal physician pleased that you had lost 15 lbs when you had your annual checkup? Please state the name of your physicians, the nature of care, the location/providers of such care, the date of such care, and whether that care is ongoing as present.
Interrogatory No. 22: Please state the name, address and phone number of your friend from Arkansas with whom you discussed gay women such as Hilary Clinton.
Interrogatory No. 23:On what date did you invite Defendant Miskin to your office to discuss lesbians? Do you discuss lesbians with other students, faculty members, or members of your church?
Interrogatory No. 24: Have you stated that you do not know much about women and would like to learn what it is to be one to students other than Miskin?
Interrogatory No. 25:Does menstruation fascinate you? Please name the article you referred to that told you that women were more sexually aroused when they had their menstrual periods. Please explain why you often asked women if they were menstruating that day.
Interrogatory No. 26: Please state whether or not you have ever pursued a romantic relationship with any student or faculty member at any institution of higher learning, and if so, the identities of those individuals and the institution at which you became acquainted with those individuals.
Interrogatory No. 27: Please identify any news articles you referred to that support the fact that women have orgasms when they breast feed their children.
Interrogatory No. 28: Please list all persons involved in sexually discriminating against a female graduate student at Argonne. Please state which of your colleagues remarked that this student was only worth what was between her legs.
Interrogatory No. 29: What is natural sex? What is unnatural sex? Please state the time frame and acts participated in that you would consider natural. Please state the time frame and acts participated in that you would consider unnatural. Please state the location/providers of such sexual acts, the date of such acts, and whether these acts are ongoing as present.
Interrogatory No. 30: Please provide each and every email sent to you and sent by you from Miskin and explain why if these emails were so disturbing to you emotionally, why you opened them in the first place once you saw the name of the sender and why if they were so disturbing did you not tell your supervisor(s)?
Interrogatory No. 31: Please state the last time you drank hard liquor and if you still enjoy five beers a week. Did you ever drink beer before phoning defendant Miskin at her home at night and if so, how many beers did you imbibe before phoning her?
Interrogatory No. 32: How many times have you asked a student or faculty member at UND to get drunk with you? Do you still have the bottle of brandy that you admitted to accepting from Miskin during the UND disciplinary hearing? Are you still keeping said brandy in reserve for her to drink with you?
Interrogatory No. 33: Do you often discuss with students peer students’ medical conditions with them? How many students did you discuss Angela’s heart condition with? How many students did you discuss the prostate cancer of student James Thomas with?
Request for Production of Documents
Request for Production No. 1: Please provide all documents requested or identified in, or referred to by you in you responses to, or utilized or referred to in the preparation of your responses to the foregoing Interrogatories.
Request for Production No. 2: Please provide copies of all phone records substantiating the exact date and time you allege Defendant called you by telephone.
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Request for Production No. 3: Please provide copies or of access for inspection to any video or audio tapes you alleges substantiate any of the claims you have made in this case.
Request for Production No. 4: Please produce copies of Plaintiff transcripts from all higher education institution ever attended by Plaintiff.