Professional Documents
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Harp Interrogatories
Harp Interrogatories
*
* IN THE CIRCUIT COURT
Plaintiffs * FOR
* BALTIMORE CITY
v. *
*
GOVERNOR LARRY HOGAN , et al. *
STATE OF MARYLAND *
100 State Circle *
Annapolis, MD 21401 *
* Case No.: 24-C-21-2999
Defendant *
*
* * * * * * * * * * * * *
INSTRUCTIONS
(a) Pursuant to Md. Rule 2-421(b), you are required to answer the
following Interrogatories within thirty (30) days after service of the Interrogatories.
(b) Also in accordance with Rule 2-421(b), your Answers shall set forth the
Interrogatory, and shall set forth the Answer to the Interrogatory “separately and fully in writing
under oath” or “shall state the grounds for refusal to answer” any Interrogatory. Your Answers
shall be signed by you.
(c) Also in accordance with Rule 2-421(b), your Answers “shall include all
information available” to you “directly or through agents, representatives, or attorneys.”
(e) If, pursuant to Rule 2-421(c), you elect to specify and produce business
records of yours in answer to any Interrogatory, your specification shall be in sufficient
detail to enable the interrogating party to locate and identify the records from which the
Answer may be ascertained.
DEFINITIONS
(e) The terms “you” and “your” refer to Maryland Secretary of Labor Tiffany M.
Robinson, together with any attorneys, agents, representatives, or persons acting on behalf of
any of the foregoing.
(f) “Agreement” refers to the Agreement Implementing the Relief for Works
Affected by Coronavirus Act between the State of Maryland and the Secretary of Labor, U.S.
Department of Labor.
(g) “CARES Act Benefits” refers to the unemployment insurance benefits provided
through the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act, codified as 15
U.S.C.
INTERROGATORIES
1. You contend that the Harp et. al. plaintiffs have not exhausted administrative remedies
regarding “on-hold” status for CARES Act Benefits, please state the basis of that
contention.
2. You contend that the Harp et. al. plaintiffs have not exhausted administrative remedies
regarding identity verification for CARES Act Benefits, please state the basis of that
contention.
3. State the criteria used by the Department of Labor when making the determination to
place a CARES Act Benefits claimant in “on-hold” status.
4. State the criteria used by the Department of Labor when making the determination to
require identity verification from a CARES Act Benefits claimant.
5. State the number of times the BEACON system has experienced technical problems
resulting in accounts being locked out or a system-wide crash.
6. State the number of claimants required to reapply through the BEACON system for
CARES Act Benefits eligibility determination between June 1, 2021, and June 10, 2021.
7. State the basis for requiring claimants to reapply through the BEACON system for a
CARES Act Benefits eligibility determination between June 1, 2021, and June 10, 2021
through the BEACON system.
8. State the number of outstanding claims for CARES Act Benefits as of September 13,
2021.
9. State the number of claims under the CARES Act currently pending identity verification.
10. State the number of claims under the CARES Act currently in “on-hold” status.
11. State the single Department of Labor point of contact established to oversee and prioritize
the resolution of claims that have not been completed within eight weeks per Labor and
Employment Article §8-109(a)(8) of the Maryland Annotated Code.
12. State the number of claims for CARES Act Benefits that have not been resolved in eight
weeks or less.
Respectfully submitted,
____________________________
Alec Summerfield, CPF #1906060002
2011 N. Charles Street
Baltimore, MD 21230
(443) 324-8644
[email protected]
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing first set of interrogatories was mailed this 14th
day of September, 2021, by certified, postage prepaid, United States Mail, on:
Christopher R. Mellott
[email protected]
Geoffrey R. Garinther
[email protected]
Ashleigh J. F. Lynn
[email protected]
Elizabeth C. Rinehart
[email protected]
Anthony J. Vitti
[email protected]
Venable LLP 750 E. Pratt Street, Suite 900
Baltimore, Maryland 21202