FILED: NEW YORK COUNTY CLERK 08/31/ :51 PM INDEX NO /2015 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 08/31/2016 EXHIBIT I

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1 FILED: NEW YORK COUNTY CLERK 08/31/ :51 PM INDEX NO /2015 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 08/31/2016 EXHIBIT I

2 By and First Class Mail Jackson Lewis P.C. 58 South Service Road, Suite 250 Melville, New York LAW OFFICE OF DANIELA NANAU, P.C. Re: Southerland v. Phoenix Constructors J.V. et al, Index No /2015 Dear Counsel: I write in response to your correspondence dated June 6, 2016 (referred to herein as "Defendants' June 6 Discovery Demands"). Below please find specific responses to the various discovery demands issued in that letter. A. Requests Made on the Record during Plaintiff's May 17, 2016 Deposition Although Defendants make a general request for all discovery that is responsive to the numerous verbal discovery demands issued to Plaintiff by defense counsel during her deposition on May 17, 2016 (see Defendants' June 6 Discovery Demands at 1), Defendants have not yet provided a copy of Plaintiff's deposition transcript to her for review to ensure that she is providing responsive discovery to all of the demands issued during her deposition. Accordingly, the discovery responses provided herein and attached hereto are responsive to only those requests defined in Defendants' June 6 Discovery Demands and what she recalls of the testimony she provided on May 17th. Plaintiff will amend her responses to Defendants' June 6 Discovery Demands, if necessary, upon receipt of her deposition transcript from Defendants.' 1. Copies of all documents (not already produced) relating to Plaintiff's efforts to secure employment since December dated March 7, Plaintiff further objects to objects to this Request on the grounds of Duplication, Undue Burden, Harassment, Custody, Control, and Vagueness. Subject to and notwithstanding the general and foregoing objections, Plaintiff avers that she has produced information responsive to similar previously issued discovery demands and will In addition to facilitating the requested discovery, Defendants are obliged to produce a copy of Plaintiff's deposition transcript for review and correction pursuant to C.P.L.R. 3116(a). To date, Plaintiff has not received a copy of her deposition transcript RUTLEDGE AVENUE, GLENDALE NY TEL: (888) FAX: (718) DNODANIELANANAU.COM IELANANALJ.COM Eadroz reit.

3 Page 2 of 4 produce documentation regarding her more recent efforts to find work on a regular basis going forward. Plaintiff anticipates being able to produce additional documentation regarding her mitigation efforts by close of business on Friday, July 8, All versions of Plaintiff's resume (not already produced) relating to the time period 2008 through the present. dated March 7, Plaintiff further objects to objects to this Request on the grounds of Duplication, Undue Burden, Harassment, Custody, Control, and Vagueness. Subject to and notwithstanding the general and foregoing objections, Plaintiff avers that she has already produced every resume for the relevant period that is in her possession. 3. Copies of all documents reflecting any and all payments Plaintiff received in connection with any Workers' Compensation claim filed by her or on her behalf. Duplication, Overbreadth, Undue Burden, Harassment, Scope, Custody, Control, Public Record and Vagueness. Plaintiff also objects to the extent that this demand seeks information protected by the attorney-client privilege or work product doctrine. Subject to and notwithstanding the general and foregoing objections, Plaintiff avers that she has previously produced documents regarding the Workers' Compensation claim she filed in connection with her position working for Defendants at the World Trade Center site, and will continue to produce all documents, as she receives them, on a regular basis. See P attached hereto, which is responsive to this Request and similar discovery demands previously issued to Plaintiff. 4. Copies of all documents reflecting any and all payments received in connection with any and all claims for Social Security Disability benefits filed by her or on her behalf. Duplication, Overbreadth, Undue Burden, Harassment, Scope, Custody, Control, Public Record and Vagueness. Plaintiff also objects to the extent that this demand seeks information protected by the attorney-client privilege or work product doctrine. Subject to and notwithstanding the general and foregoing objections, Plaintiff avers that she has produced all documents regarding Social Security Disability income payments that she has received, and will continue to produce all documents regarding the Social Security Disability income, as she receives them, on a regular basis.

4 Page 3 of 4 5. Copies of any and all correspondence between Plaintiff and the U.S. Equal Employment Opportunity Commission. dated March 7, Plaintiff further objects to this Request on the grounds of Duplication, Overbreadth, Undue Burden, Harassment, Scope, Custody, Control, and Vagueness. Subject to and notwithstanding the general and foregoing objections, Plaintiff avers that she has already produced correspondence she has sent to or received from the U.S. Equal Employment Opportunity Commission that is in her possession. To the extent that Plaintiff testified regarding additional correspondence with the EEOC that has not been produced, Plaintiff requests the opportunity to review her deposition transcript to determine whether she has in her possession any other documents that are responsive to this demand, and similar discovery demands previously issued by Defendants. 6. Copies of any and all tax returns filed by Plaintiff from 2008 to the present. Duplication, Overbreadth, Undue Burden, Harassment, and Scope. 13. Contact Information For Witnesses Pursuant to the Preliminary Conference Order, dated July 30, 2015, which was modified by subsequent agreement by the parties, Plaintiff timely identified witnesses with information relevant to her claims in correspondence served on Defendants on November 29, Below are the last known physical and electronic addresses for two witnesses identified in Plaintiff's correspondence regarding relevant witnesses to this action: Charles Davis Last known address: rd Avenue, Queens Village, NY Last known address: cedavis7916agmail.com Elisa Spivey Last known address: 674 Eastern Parkway, Brooklyn, NY Last known address: elisiaspivey@gmail.com Plaintiff will provide the addresses in her possession for any other third-party witness who she testified about at her deposition on May 17, 2016 once she can review the deposition transcript.

5 Page 4 of 4 C. Subpoena for Shawn Billups Plaintiff's counsel hereby accepts service of Mr. Billups' deposition subpoena and suggests Monday, July 18, 2016 or Monday, July 25, 2016 as dates for his deposition. Please confirm the date at your earliest convenience as well as the start time and location for this deposition. Additional Responsive Documents Attached hereto please find copies of notebooks that Plaintiff kept during the time she worked for Defendants at the World Trade Center site. These documents, which have the Bates stamp range P , are responsive to Defendants' Discovery Demand Nos. I and 20. E. Information Requested in dated June 14, 2016 In an Ms. Dobson sent to me on June 14, 2016, Defendants issued an additional discovery demand requested an "itemized calculation of Plaintiffs damages," which seeks similar information to what was solicited by Defendants' Interrogatory No. 4, a discovery demand that Plaintiff has responded to. In responding to this additional discovery demand, Plaintiff incorporates all of the previously raised General Objections to this Request for Documents, as defined in her Responses to Defendants' Discovery Demands, dated March 7, Plaintiff further objects to this Request on the grounds of Duplication, Overbreadth, Undue Burden, Harassment, Scope, Custody, Control, and Vagueness. Subject to and notwithstanding the general and foregoing objections, Plaintiff will provide a calculation of her economic damages to date and produce that information to Defendants by close of business on Monday, July 11, Plaintiff has also made claims for emotional distress and punitive damages, which are, as you know, to be determined by the fact-finder. If you have any questions regarding the matters discussed herein, please do not hesitate to contact me. I would appreciate it if you would confirm the date of Shawn Billups' deposition by close of business on Thursday, July 7, 2016 so that we may plan accordingly. Attachments (by only)