OHALLORAN KOSOFF GEITNER & COOK, LLC

ATTORNEYS AT LAW
EDENS CORPORATE CENTER
650 DUNDEE ROAD, FOURTH FLOOR
NORTHBROOK, ILLINOIS 60062
PHONE (847) 291-0200
FAX (847) 291-9230

Senders email:
jabern@okgc.com
www.okgc.com
June 18, 2010

Via U.S. Mail and E-Mail

Mark McCoy
31 Grandview Drive
Collinsville, IL 62234

Re: Mark McCoy v. City of Fairview Heights, et al.

Case No. 2010 L 75

Dear Mr. McCoy:

I am in receipt of your responses to the discovery issued by my client in the above referenced
case. I am writing pursuant to Illinois Supreme Court Rule 201(k) regarding several deficiencies
in your responses. Please see below regarding our specific requests that you supplement your
responses accordingly. I look forward to your responses. Feel free to call or otherwise contact
me with any questions or concerns.

City of Fairview Heights Interrogatories

#9: Your objection is unfounded. Prior personal injury is directly relevant to this matter as it
could go to show that the injuries sustained were unrelated to the incident at issue. I am willing
to limit this request to any personal injury or prolonged serious and/or chronic illness to the same
parts of the body for which you claim you were injured in this matter. Please supplement your
response.

#11: Your objection is unfounded. Your medical history is relevant as you are claiming medical
damages in this case. By claiming medical injuries, you have put your medical history at issue.
The interrogatory only calls for information regarding physicians seen within the past 5 years.
This is not burdensome or overbroad as you claim. Please supplement your response.

#14: Your objection is unfounded. Convictions as called for in this interrogatory are admissible
as evidence of character. Please supplement your response.

#15: Your objection is unfounded. Prior personal injury or civil rights litigation could
reasonably lead to the discovery of admissible evidence. Please supplement your response.
Mr. Mark McCoy
June 21, 2010
Page 2

#22: Your objection is unfounded and your answer is incomplete. The interrogatory calls for the
reason for the contact with the Fairview Heights police department, which you have not included
in your response. Additionally, all contact with the Fairview Heights police would be relevant in
this matter. Please supplement your response.

Aaron Nymans Interrogatories

#7 & 8: Your objection is unfounded. Whether you consumed alcoholic beverages or a

controlled substance is directly relevant to your state of mind. Additionally, Officer Alemond
observed you to be weaving in your traffic lane and suspected that you were intoxicated. Please
supplement your response.

Please provide complete responses as detailed above within 14 days of receipt of this letter.
Thank you in advance for your cooperation.

Very truly yours,

O'HALLORAN KOSOFF GEITNER & COOK, LLC

s/Joshua S. Abern

Joshua S. Abern
JSA/krf