- Please admit that New Jersey’s stun gun/Taser ban is unconstitutional.
- Please admit that New Jersey conceded that the stun gun/Taser ban was unconstitutional.
- Please admit that New Jersey continues to enforce the stun gun/Taser ban.
- Please state how many criminal cases for stun guns and/or Tasers New Jersey prosecuted in the past two years.
- Please state how many permits to carry are active as of the date on this pleading in New Jersey.
- Please state, out of those active permits, what the “justifiable need” basis was to issue that permit.
- Please state, out of those numbers of active permits in Interrogatory Number 4, the race, gender, and age of each of those active permits.
- Please state the factual and legal basis for all of your defenses and affirmative defenses pled in your Answer, and identify all witnesses, facts, opinions and documents which you contend supports your position(s).
Request for Production:
- Please provide a copy of all draft and/or final electronic control device statutes or regulations that New Jersey seeks to implement.
- Please provide a copy of all documents that have any relevance or are reasonably calculated to lead to the identification of any document relevant to the claims or defenses in this lawsuit.
New Jersey has thirty (30) days to respond to the requests.