Unveiling the truth through interrogatories

ClickHERSHEY'S REQUIRED SWORN ANSWERS
Rakestraw v. The Hershey Company, et al. — Case No. 2:25-cv-02682-JWB-TJJ
Navigating the complexities
LEGAL DISCLAIMER
This website discusses a pending lawsuit. The claims described are allegations made in a court filing and have not yet been proven. The defendant denies liability. This content is for informational purposes only and is not legal advice.
WHAT ARE INTERROGATORIES?
Interrogatories are formal written questions that the opposing party must answer in writing under oath within 30 days of service. Unlike document requests, interrogatories require Defendants to provide sworn written answers identifying who made decisions, why those decisions were made, and who had knowledge of relevant facts. False answers constitute perjury.
These 31 interrogatories are prepared and ready to deploy the moment discovery opens following the Court's ruling on the pending Motion to Dismiss.
WHERE THIS CASE STANDS
Defendants filed a Motion to Dismiss on January 27, 2026. That motion is pending before Judge John W. Broomes in the United States District Court for the District of Kansas. Discovery is stayed until Judge Broomes rules. These interrogatories will be served on Defendants on the first day discovery opens.
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS
DONNIE LEE RAKESTRAW, JR., Plaintiff,
v. Case No. 2:25-cv-02682-JWB-TJJ
THE HERSHEY COMPANY, et al., Defendants.
PLAINTIFF DONNIE LEE RAKESTRAW, JR.'S
FIRST SET OF INTERROGATORIES TO DEFENDANTS
(Pursuant to Fed. R. Civ. P. 33)
Plaintiff Donnie Lee Rakestraw, Jr., appearing pro se, requests that Defendants answer the following interrogatories separately, fully, and under oath within thirty (30) days of service, pursuant to Federal Rule of Civil Procedure 33.
DEFINITIONS
"You" or "Defendants" means The Hershey Company and its officers, agents, employees, managers, supervisors, and representatives including but not limited to Lee Timmons, Karen Powell, and Bill Maloy.
"Plaintiff" refers to Donnie Lee Rakestraw, Jr.
"Edgerton Facility" refers to the pretzel manufacturing facility located in Edgerton, Kansas.
"Relevant period" means March 1, 2024 through May 31, 2024 unless otherwise specified.
INSTRUCTIONS
Each interrogatory must be answered separately and fully in writing under oath.
If you object to any interrogatory, state the specific grounds for objection and answer to the extent not objected to.
If any information is withheld on privilege grounds, identify the privilege claimed and provide sufficient information to assess the claim.
These interrogatories are continuing in nature and must be supplemented under Rule 26(e) if additional information becomes available.
INTERROGATORIES
Interrogatory No. 1 — Safety Mat Requests
Identify by name, title, and role every person who received, was informed of, or participated in any decision regarding Plaintiff's request for anti-fatigue safety mats, and describe each person's involvement in that decision including the date and outcome.
Interrogatory No. 2 — Safety Mat Decision
Identify every person who participated in the decision not to provide anti-fatigue mats to Plaintiff, state the reasons for that decision, identify any documents reflecting that decision, and state whether any similar requests by other employees were granted or denied during the same period.
Interrogatory No. 3 — Injury File
Identify every person who created, received, reviewed, or maintained any document relating to Plaintiff's foot injury, state the date each person first became aware of the injury, and describe what action if any each person took in response.
Interrogatory No. 4 — Medical Treatment Decision
Identify every person involved in any decision regarding whether Plaintiff would receive medical evaluation or treatment after reporting his injury, state the reasons for any decision to deny treatment, and identify any policy or procedure that governed that decision.
Interrogatory No. 5 — Forklift Assignment
Identify every person who made or approved any decision or instruction regarding Plaintiff operating a forklift after his injury was reported, state the reasons for that decision, and identify any documents reflecting that decision.
Interrogatory No. 6 — Donning and Doffing Policy
Describe in detail Defendants' policy regarding the time at which employees were required to be present on the production floor and ready to work relative to their scheduled shift start time, identify all persons responsible for implementing and enforcing that policy, and state whether employees were compensated for time spent completing required sanitation and PPE donning procedures before their recorded clock-in time.
Interrogatory No. 7 — Safety Policy Enforcement
Identify every person responsible for enforcing safety policies applicable to Plaintiff's work area during the relevant period, describe how those policies were communicated to employees and supervisors, and identify any instance during the relevant period where those policies were not followed.
Interrogatory No. 8 — Safety Policy Deviations
Identify every known instance during the relevant period where safety policies applicable to Plaintiff's department were not followed, state who was responsible for the deviation, and describe what action if any was taken in response.
Interrogatory No. 9 — Awareness of Plaintiff's Injury
Identify by name and title every supervisor, manager, HR representative, and safety personnel who had knowledge of Plaintiff's foot injury during the relevant period, state the date each person first became aware of the injury, and describe how each person learned of it.
Interrogatory No. 10 — Accommodation Requests
Identify every person who received, reviewed, or participated in any decision regarding Plaintiff's requests for reasonable accommodation or modified duties, describe each request and the response, and identify any policy or procedure that governed the accommodation process.
Interrogatory No. 11 — Oven Room Assignments
Identify every person who made or approved decisions regarding Plaintiff's assignment to the oven room, state the reasons for those assignments, and identify any person who had authority to modify those assignments.
Interrogatory No. 12 — Workstation Assignments
Describe the process by which workstation assignments were determined for employees in Plaintiff's department, identify every person with authority to make or modify those assignments, and state whether Plaintiff's known disability was considered in making those assignments.
Interrogatory No. 13 — Post-Injury Work Assignments
Identify every person involved in decisions regarding Plaintiff's work assignments after his injury was reported, describe any communications among supervisors, managers, or HR regarding those assignments, and state whether any accommodation was considered in connection with those assignments.
Interrogatory No. 14 — Termination Decision
Identify every person who participated in or approved the decision to terminate Plaintiff's employment, state the reasons given for that termination, identify all documents reflecting that decision, and state whether Plaintiff's injury report or accommodation requests were considered in connection with that decision.
Interrogatory No. 15 — Records Retention Policy
Describe Defendants' policies governing the retention and preservation of emails, HR records, and safety records, identify the person responsible for implementing those policies at the Edgerton Facility, and state what steps were taken to preserve records relating to Plaintiff following the initiation of this litigation.
Interrogatory No. 16 — Litigation Hold
Identify every person who received a litigation hold notice relating to Plaintiff's claims, state the date each notice was issued, describe what categories of documents were subject to the hold, and identify any documents that were destroyed after the hold was issued.
Interrogatory No. 17 — Safety and Ergonomic Training
Identify every safety or ergonomic training program provided to employees and supervisors at the Edgerton Facility during the relevant period, state the date and content of each program, identify every person who completed each program, and describe how completion was documented.
Interrogatory No. 18 — Chain of Command
Identify by name and title every person in the supervisory and management chain of command applicable to Plaintiff during the relevant period, describe each person's responsibilities, and identify who had final authority over Plaintiff's work assignments, accommodation requests, and termination.
Interrogatory No. 19 — Similarly Situated Employees
Identify all employees who worked in Plaintiff's department, production line, workstation area, or shift during the relevant period, state each employee's job title and shift, and identify which employees were subject to the same donning and doffing requirements as Plaintiff.
Interrogatory No. 20 — Oven Room Complaints
Identify every complaint, report, or investigation concerning the oven room or Plaintiff's workstation during the relevant period, state who made each complaint, describe the nature of each complaint, and identify what action if any was taken in response.
Interrogatory No. 21 — Lee Timmons Training
Identify every safety training program, accommodation procedure training, or pre-shift procedure training that Lee Timmons was required to complete, state the date each training was completed, identify how completion was documented, and describe any discrepancies between training completion records and actual attendance or participation.
Interrogatory No. 22 — Facility Layout
Describe the physical layout of the Edgerton Facility relevant to Plaintiff's work area, including the location of the time clock relative to the sanitation area and production floor entrance, the location of anti-fatigue mat storage, and the location of any surveillance cameras covering the sanitation area and production floor entrance.
Interrogatory No. 23 — Personnel File
Identify every document contained in Plaintiff's personnel file, state the date each document was created, and identify every person who created, reviewed, or made entries into that file during Plaintiff's employment.
Interrogatory No. 24 — Visual Records
Identify all photographs, videos, or visual records of the oven room, Plaintiff's workstation, production area, or mat storage locations that exist or existed during the relevant period, state where each is maintained, and identify any that were destroyed after the initiation of this litigation.
Interrogatory No. 25 — OSHA Compliance
Describe Defendants' OSHA reporting and compliance procedures at the Edgerton Facility, identify every person responsible for OSHA compliance during the relevant period, state whether a mandatory injury report was filed in connection with Plaintiff's foot injury, and if not state the reasons why no report was filed.
Interrogatory No. 26 — Injury Reporting and Classification
Describe the process by which workplace injuries are reported, classified, investigated, and referred for treatment at the Edgerton Facility, identify every person involved in classifying Plaintiff's injury as not work-related, and state the basis for that classification.
Interrogatory No. 27 — Lee Timmons Communications
Identify every communication sent by, received by, or concerning Lee Timmons regarding Plaintiff from March 1, 2024 through May 31, 2024, state the date and substance of each communication, and identify every person who was a party to or recipient of each communication.
Interrogatory No. 28 — Safety Incentive Programs
Describe any vendor bucks, rewards, incentive programs, or recognition programs tied to safety performance or stretching programs at the Edgerton Facility during the relevant period, identify every person responsible for administering those programs, and state whether safety incident rates affected any employee's compensation, bonus, or recognition during that period.
Interrogatory No. 29 — Employee Complaints and Legal Matters
Identify every employee complaint, accommodation request, EEOC charge, workers compensation claim, settlement, or legal matter involving employees at the Edgerton Facility from January 1, 2023 through the present, state the nature of each matter, identify the employees involved, and describe how each matter was resolved.
Interrogatory No. 30 — Work Assignment Process
Describe in detail the process by which work assignments were determined, created, approved, and modified in Plaintiff's department, identify every person with authority to make or modify assignments, and state whether any written policy governed the assignment process.
Interrogatory No. 31 — Internal Investigations
Identify every internal investigation, safety review, incident review, root cause analysis, risk assessment, or management discussion concerning Plaintiff's injury, the oven room or workstation, anti-fatigue mats, or any alleged safety condition affecting Plaintiff, state the date and outcome of each, identify every person involved, and identify all documents generated in connection with each.