Case 3:12-cv-30051-MAP Document 163 Filed 06/11/15 Page 1 of 3 Case 3:12-cv-30051-MAP Document 163 Filed 06/11/15 Page 2 of 3 Case 3:12-cv-30051-MAP Document 163 Filed 06/11/15 Page 3 of 3 Case 3:12-cv-30051-MAP Document 163-1 Filed 06/11/15 Page 1 of 130 EXHIBIT A Case 3:12-cv-30051-MAP Document 163-1 Filed 06/11/15 Page 2 of 130 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS SPRINGFIELD DIVISION SEXUAL MINORITIES UGANDA, ) ) Plaintiff, ) Civil Action No. ) v. ) 3:12-CV-30051 ) SCOTT LIVELY, individually and as ) President of Abiding Truth ) Ministries, ) ) Defendant. ) PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT SCOTT LIVELY Pursuant to Rule 33 of the Federal Rules of Civil Procedure and Local Rule 33.1, Plaintiff Sexual Minorities Uganda hereby requests that Defendant Scott Lively answer fully, in writing and under oath, each of the following interrogatories, and serve such answers on the undersigned counsel for the Plaintiff within 30 days after service of these requests. DEFINITIONS 1. “Plaintiff” means Sexual Minorities Uganda (“SMUG”). 2. “Defendant,” “you,” and “your” mean Defendant Scott Lively, in his individual capacity and in the capacity in which he acted on behalf of any entity or association, or their affiliates and subsidiaries, including but not limited to Abiding Truth Ministries as alleged in Paragraph 22 of your Answer. 3. “Answer” means Defendant Scott Lively’s Answer and Defenses to Plaintiff’s First Amended Complaint, dated November 20, 2013. Case 3:12-cv-30051-MAP Document 163-1 Filed 06/11/15 Page 3 of 130 4. “Document” is defined to mean and include “documents or electronically stored information” as used in Fed. R. Civ. P. 34(a)(1)(A) and Local Rule 26.5(c)(2), and “communications” as used in Local Rule 26.5(c)(1), including but not limited to e-mails, video and/or audio recordings, records of information transmitted via meetings or telephone conversations, letters, correspondence, notes, facsimiles, and other internet-based communications, including on social media platforms (i.e., Facebook, Twitter, or similar), or other forms of verbal and/or communicative intercourse. 5. “Identify,” a. with respect to persons, is defined to be synonymous in meaning and equal in scope to the usage of the term in Local Rule 26.5(c)(3); b. with respect to documents, is defined to be synonymous in meaning and equal in scope to the usage of the term in Local Rule 26.5(c)(4); and c. with respect to location, means a description of the venue as well as its physical address. 6. “Including” shall always be construed to mean “including, but not limited to,” or “including, without limitation.” 7. “Relating to” means in any way, directly or indirectly, alluding to, amending, assisting with, cancelling, commenting on, comprising, concerning, confirming, considering, constituting, contradicting, describing, discussing, endorsing, evidencing, identifying, incorporating, mentioning, modifying, negating, pertaining to, qualifying, referring to, reflecting, regarding, relevant to, representing, revoking, showing, suggesting, supplementing, supporting, terminating, underlying, or otherwise involving the subject matter of the specific request. 2 Case 3:12-cv-30051-MAP Document 163-1 Filed 06/11/15 Page 4 of 130 8. “Person” is defined to be synonymous in meaning and equal in scope to the usage of the term in Local Rule 26.5(c)(6), and is also defined to include any entity or association. 9. “State the basis” is defined to be synonymous in meaning and equal in scope to the usage of the term in Local Rule 26.5(c)(8). 10. “Lawsuit” refers to the lawsuit entitled Sexual Minorities Uganda v. Scott Lively, in the United States District Court, District of Massachusetts, Civil Action No. 3:12-CV-30051, and shall include all claims asserted therein. 11. “Gay movement” and “gay agenda” as used herein are given the same meaning as those terms are used in Defendant’s book Redeeming the Rainbow. 12. “Pro-family” as used herein has the same meaning as that term is used in your Answer. 13. “Anti-Homosexuality Bill” refers to the legislation concerning homosexuality first introduced in the Ugandan Parliament in 2009 and eventually signed into law by the President of Uganda on or about February 24, 2014, including any and all drafts and versions thereof and proposed amendments thereto. 14. The “Relevant Date Range” unless otherwise specified refers to the period of time between January 1, 2002 to the present, including any portion thereof. INSTRUCTIONS 1. Each Interrogatory must be answered separately, fully, and completely. If you cannot answer any Interrogatory fully and completely after exercising due diligence to make inquiry and to secure the information to do so, please so state and answer such Interrogatory to the extent that you are able, and further specify the facts on which you rely to support the contention that you are unable to answer the Interrogatory fully and completely. State any knowledge, information, or belief you have concerning the unanswered portion of such 3 Case 3:12-cv-30051-MAP Document 163-1 Filed 06/11/15 Page 5 of 130 Interrogatory, and state fully, completely, and in detail the acts done and the inquiries made by you to show that you have exercised due diligence to make inquiry and to secure the information necessary to answer that Interrogatory. 2. If you answer any Interrogatory by reference to records from which the answer may be derived or ascertained, as permitted by Federal Rule of Civil Procedure 33(c), you must follow the steps outlined in Local Rule 33.1(b). 3. If you object to any Interrogatory, you should: (i) identify the portion of such Interrogatory claimed to be objectionable and state the nature and basis of the objection; (ii) identify any such information withheld pursuant to such objection with sufficient particularity and in sufficient detail to permit the Court to determine whether the information falls within the scope of such objection; and (iii) answer any portion of such Interrogatory that is not claimed to be objectionable. 4. If you assert a claim of privilege with respect to any Interrogatory, or a portion thereof, you must identify the nature of the privilege (including work product) that is being claimed and, if the privilege is governed by state law, indicate the state’s privilege rule being invoked. You must also provide the following information in the objection: a. For documents: (i) the type of document, e.g., letter or memorandum; (ii) the general subject matter of the document; (iii) the date of the document; and (iv) the author of the document, the addressees of the document, and any other recipients, and, where not apparent, the relationship of the author, addressees, and recipients to each other; b. For oral communications: (i) the name of the person making the communication and the names of persons present while the communication was made and, where 4 Case 3:12-cv-30051-MAP Document 163-1 Filed 06/11/15 Page 6 of 130 not apparent, the relationship of the persons present to the person making the communication; (ii) the date and place of communication; and (iii) the general subject matter of the communication. 5. In answering each of these Interrogatories, identify all documents and persons relied upon or which provide a basis for the answer given. 6. The terms “and,” “or,” and “and/or” have both conjunctive and disjunctive meanings, and the terms “each,” “any,” and “all” mean “each and every.” 7. Any singular term will be deemed to include the plural, and any plural term the singular. All pronouns and variations thereof will be deemed to refer to the feminine, masculine or neuter, singular or plural, as the identity of the person or thing referred to requires. 8. Unless otherwise specified, the relevant date range for information responsive to these Interrogatories includes any information created between January 1, 2002 to the present. INTERROGATORIES Interrogatory No. 1: Describe your understanding of the causes of homosexuality or so-called homosexual behavior and the harm resulting from homosexuality or so-called homosexual behavior, and identify all sources upon which you rely as the basis for such description. Interrogatory No. 2: Identify all methods that you have advocated be used by governments or society to treat, discourage, or eliminate homosexuality, so-called homosexual behavior, the so-called promotion of homosexuality or homosexual behavior, or the “gay movement,” and identify all speeches or writings in which you have referenced or described each method. 5 Case 3:12-cv-30051-MAP Document 163-1 Filed 06/11/15 Page 7 of 130 Interrogatory No. 3: State the basis for your statements relating to the relationship or link between the Rwandan genocide and homosexuality or so-called homosexual behavior, for example, your statement in or around March 2009 in Kampala that “a mass murder, you know like…the Rwandan stuff, probably involved these guys,” as shown in “Scott Lively Fanning Anti-Gay Flames in Uganda” (Video), http://www.youtube.com/watch?v=BTcI6YssQ1w (last accessed March 24, 2014), and identify all speeches or writings in which you made statements relating to this relationship. Interrogatory No. 4: State the basis for your statements in Redeeming the Rainbow referring to the “homosexual recruitment of children,” and identify all speeches or writings in which you made similar statements. Interrogatory No. 5: State the basis for your statements in your lecture at the “Seminar on Exposing the Homosexual Agenda” in Uganda in March 2009 connecting homosexuality or so-called homosexual behavior with child abuse, and identify all speeches or writings in which you made similar statements.