Huon v. Breaking Media et al

Filing 194

RESPONSE by Meanith Huonin Opposition to MOTION by Defendants John Lerner, Breaking Media, Breaking Media, LLC, David Lat, Breaking Media, Inc., David Minkin, Elie Mystal to dismiss Plaintiff's Fourth Amended Complaint 178 WITH EXHIBITS A TO J (Attachments: # 1 Exhibit A1, # 2 Exhibit A2, # 3 Exhibit A3, # 4 Exhibit A4, # 5 Exhibit A5, # 6 Exhibit A6, # 7 Exhibit B, # 8 Exhibit C, # 9 Exhibit D, # 10 Exhibit E1, # 11 Exhibit E2, # 12 Exhibit E3, # 13 Exhibit F, # 14 Exhibit G, # 15 Exhibit H, # 16 Exhibit I, # 17 Exhibit J)(Huon, Meanith) (Attachment 15 Exhibit H replaced on 3/19/2013 pursuant to Judge's order of 3/18/2013) (tg, ).

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
MEANITH HUON,
Plaintiff,

v.
FORMER MADISON COUNTY STATE'S
ATTORNEY WILLIAM MUDGE, et al,
Defendants.

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Case No.: 12 cv 166 MJR PMF

DEFENDANT CHRIS HOELL'S ANSWERS TO PLAINTIFF'S INTERROGATORIES

NOW COME Defendant, Chris Hoell, by and through his counsel, John Gilbert, and for
his Answer to Plaintiffs Interrogatories, states as follows:
1.
Please state your full name, address, date and place of birth, employer, job title, and job
duties.
ANSWER:

Christopher R. Hoell; Missouri Attorney General's Office.

Mr. Hoell can be

contacted through his undersigned counsel.

2.
Please state the name and address for each of your employers for the past ten (10) years
and for each also state:
(a)
(b)
(c)

the inclusive dates of employment at such place of employment;
the reason for leaving each such place of employment; and
the nature of your work and duties.

ANSWER:

Defendant is presently employed at the Missouri Attorney General's Office.

Defendant's previous employment includes the Madison County State's Attorney's Office
beginning in December of 2007. The Kagen Law Firm, Clayton, MO, March 2007-November
2007, criminal defense firm.

Jefferson County Prosecuting Attorney's Office, Hillsboro,

Missouri, October 2003-0ctober 2007, prosecuted misdemeanors and felonies. Prior to that,
Brasher Law Firm, a civil defense firm.

130346339vl 0925867

3.
Have you received any special training for the position of assistant state's attorney for the
Madison County State's Attorney's office? If so, state:
(a)
the nature and substance of the training you received;
(b)
the inclusive dates of the period during which you received training;
(c)
the name and address of each and any specialized school you attended to receive such
training;
(d)
the dates of attendance at each such specialized school;
(e)
the nature and substance ofthe training offered at each such specialized school;
(f)
the degree or certificate, if any, that you received from each such specialized school.
ANSWER:

Defendant objects to this interrogatory as overly broad and not reasonably

calculated to lead to the discovery of admissible evidence. Without waiving said objection and
subject thereto, yes.

CLE and work related trainings, including: Trial Advocacy-National

Advocacy Center, Advanced Trial Advocacy-Illinois Appellate Prosecutor, Trial School-Missouri
Office of Prosecution Services, Protecting Children Online-National Center for Missing and
Exploited Children, Crimes Against Children-Dallas Police Department, Prosecuting Child
Abuse Cases-National Advocacy Center, Reconstruction of Injuries in

Child Abuse

Investigations-John Reid & Associates, Computer-Facilitated Crimes Against Children-John

Reid & Associates, Anatomy of Criminal Sexual Assault-Illinois State Bar Association, What
Criminal Court Judges Want You to Know-NBI, Inc.

4.
State what investigation you made into the facts of 2008 CF 1496, including whether you
interviewed witnesses on the scene and reviewed the detectives' street files and files.
ANSWER:

Defendant did not investigate the case identified in this interrogatory as he is not a

detective or law enforcement officer. Defendant did review the reports provided to the State
Attorney's Office by detectives for the Madison County Sheriff's Office and speak to detectives
for the Madison County Sheriff's Office.

5.
State what investigation you made into the facts of2009 CF 1688, including al [sic} facts
to support the claim that plaintiff had committed a forcible felony while out on bond.

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