IN THE CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA

SPENCER COLLIER,
Plaintiff
v.
ROBERT BENTLEY; et. al.

Defendants.

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03-CV-2016-900538

PLAINTIFFS FIRST DISCOVERY REQUESTS TO DEFENDANT BENTLEY

Pursuant to Rules 33 and 34 of the Alabama Rules of Civil Procedure, Plaintiff requests
that Defendant Bentley respond to the following Interrogatories and Requests for Production
within the time required by law:
INTERROGATORIES
1. State your full name.
2. At any time from January 1, 2014, through March 30, 2016, was Rebekah Mason a State
employee?
3. What were Rebekah Masons job duties as your Senior Political Advisor?
4. Who hired Rebekah Mason to be your Senior Political Advisor?
5. Who paid Rebekah Mason to be your Senior Political Advisor?
6. How many hours a week did Rebekah Mason work as your Senior Political Advisor?

7. Did you provide a letter or certificate of appointment to Rebekah Mason for the position
of Senior Political Advisor to Governor Bentley or any other position with the Governors
Office?
8. Identify every person who supervised Rebekah Mason in her role as Senior Political
Advisor.
9. Identify any persons, firms, corporations, or other entities who were the employers,
masters, or principals of Defendant Mason from January 1, 2010 through March 30, 2016.
10. Since March 30, 2016, has Rebekah Mason provided any political advice to you? If so,
who paid her?
11. Did you ever ask any persons, firms, corporations or other entities to contribute money
ACEGOV?
12. Identify any persons, firms, corporations or other entities who contributed money
directly or indirectly to Defendant Mason, whether by cash, check, PayPal, or provided
any other benefits to Defendant Mason, through RCM or any of Defendant Masons
businesses; any of Jon Masons businesses; ACEGOV; Bentley for Governor, Inc.; and
Defendant Bentley personally.
13. Did you instruct anyone to provide Rebekah Mason with a parking place at the Capitol?
If so, whom.
14. Who provided Rebekah Mason with a parking place at the Capitol?
15. Did you instruct anyone to provide Rebekah Mason with card key access to any of the
Capitol buildings? If so, whom.
16. Who provided Rebekah Mason with card key access to any of the Capitol buildings?

17. Provide the number and provider for each cell phone you used from January 1, 2010 to
present.
18. Attached as Exhibit A is a Statement from www.governor.alabama.gov dated March 22,
2016, entitled Governor Bentley Announces Termination of Spencer Collier as Alabama
Law Enforcement Agency Secretary. In that Statement you are quoted as saying After
placing Spencer on medical leave a few weeks ago to allow him to recover from back
surgery, Acting ALEA Secretary Stan Stabler identified several areas of concern in the
operations, policies and procedures at ALEA. State each of the areas of concern that
ALEA Secretary Stan Stabler identified to you and whether any documents were provided
to you to support Stablers concerns.
19. In the Statement attached as Exhibit A you were also quoted as saying After an internal
review, the ALEA Integrity Unit found a number of issues, including possible misuse of
state funds. With respect to that quote, state the following:
A.

The name and job title of each member of the ALEA Integrity Unit who

participated in the internal review.

B.

The issues that were identified.

C.

The possible misuse of state funds to which you were referring.

D.

Whether you had reviewed any documents related to this internal review.

E.

The person who would have the most information about this internal

review.
20. Attached as Exhibit B is a Statement from www.governor.alabama.gov dated April 19,
2016, entitled Governor Bentley Releases Statement on Collier Lawsuit. In that
Statement you are quoted as saying Mr. Collier was terminated of his duties as ALEA

for cause. Once the facts and circumstances become public, I am confident that the
justification for terminating him will be shown. State all of the facts and circumstances
that you were referring to in that statement.
21. With respect to Exhibit B, also state in detail the cause you were referring to.
22. With respect to Exhibit B, also state in detail everything you claim justified Colliers
termination.
23. Did you order Collier not to submit a sworn statement in the Mike Hubbard case?

REQUESTS FOR PRODUCTION

1. A copy of the internal review and/or all documents related to the review you identified
in the Statement from www.governor.alabama.gov dated March 22, 2016, entitled
Governor Bentley Announces Termination of Spencer Collier as Alabama Law
Enforcement Agency Secretary.
2. Any and all documents, emails, reports, memorandums, correspondence, photographs,
videotapes and/or electronic recordings in your possession, custody and/or control which
relate to any of the facts contained in the Plaintiffs complaint.
3. All emails, texts, correspondence, documents, memorandums and/or any writings between
you and Rebekah Mason that relate in any way to Spencer Collier.
4. All emails, texts, correspondence, documents, memorandums and any writings between
you and Stan Stabler that relate in any way to Spencer Collier.

5. Any and all cell phone records, including those of burner phones that you used from
January 1, 2010 to present, including, but not limited to, any receipts involving the
purchase of any bills and any payment information relating to these phones from January
1, 2010 to present.
S/ Kenneth J. Mendelsohn
Kenneth J. Mendelsohn (MEN 001)
Attorney for Plaintiff
OF COUNSEL:
JEMISON & MENDELSOHN
1772 Platt Place
Montgomery, Alabama 36117
(334) 213-2323 (Telephone)
(334) 213-5663 (Facsimile)
Email: kenny@jmfirm.com
Law Offices of Tommy James
2700 Corporate Drive, Suite 200
Birmingham, Alabama 35242
Tjameslaw1@gmail.com

CERTIFICATE OF SERVICE
I certify that on June 20, 2016, Notice of the Filing of the foregoing has been served on
all counsel of record via the Courts Alafile system and a copy has been served by email:

s/Kenneth Mendelsohn
OF COUNSEL

John C. Neiman, Jr.

Stephanie Houston Mays
Mark D. Foley, Jr.
Maynard Cooper & Gale
1901 6th Avenue N., Suite 2400
Birmingham, Alabama 35203-2602
jneiman@maynardcooper.com

Joseph C. Espy, III

Benjamin J. Espy
William M. Espy
MELTON, ESPY & WILLIAMS, P.C.
P.O. Drawer 5130
Montgomery, Alabama 36103
Telephone: 334-263-6621
jespy@mewlegal.com
bespy@mewlegal.com
wespy@mewlegal.com

Robert D. Segall
Ashley N. Penhale
Copeland, Franco, Screws & Gill, P.A.
Post Office Box 347
Montgomery, Alabama 36101-0347
Phone: (334) 834-1180
Fax: (334) 834-3172
Email: segall@copelandfranco.com
Email: penhale@copelandfranco.com

William P. Gray, Jr.

Douglas N. Robertson
GRAY & ASSOCIATES, L.L.C
WPG@grayattorneys.com
David B. Byrne, Jr.
Office of the Governor
david.byrne@governor.alabama.gov