This is adapted from The First Set of Interrogatories
of Marie O'Hara
(page numbers 369-370, case number: CV 191-CC-2880 filed on
December 20, 1993 in the Greene County Court House in Springfield,
Some slight modifications have been made in order accommodate Internet
presentation and preserve privacy.
The incident described occurred on October 1, 1992 and preceded the
"break-in" by the Polk County Sheriff's Department on October 2, 1992 --
which is also described beginning on page 370.
The First Set of Interrogatories - December 20, 1993
Question 31 (Page 369-370)
With regard to all communications of any kind relating to the subject matter
of the above-entitled action, both oral and written, that you contend occurred
between yourself and a local, state, or federal agency:
(a) Set forth the date when each such communication was made;
October 1, 1992
(b) Set forth the place(s) communication occurred;
On porch of Marie O'Hara's residence, phone conversation to City Hall.
(c) Identify each and every person making and receiving each such communication;
Marie O'Hara, Patty Reynolds, Bolivar Police Chief Steve Brown,
[another] Police Officer, and my caregiver.
(d) Identify each person present when each such communication occurred;
Marie O'Hara, Patty Reynolds, Police Chief Steve Brown, [another]
Police Officer, and my caregiver.
(e) If oral, set forth the substance of the communication, and attach a true copy
of any documents reducing any part of the oral communications to writing,
or otherwise referencing the communication;
Bolivar Police Chief Steve Brown, another Police Officer and Patty Reynolds
(Head of the Division of Aging for the State of Missouri), demanded entry
into my isolation room, saying that in cooperation with Empire Electric,
they wanted to see if I were dead, following the incident the day before,
(September 30, 1992) in which Empire Electric discontinued my electricity
(for eight hours) in spite of a Medical Disability Award from the Social
Security Disability and faxed letters from doctors and my attorney that
such action was life-threatening due to my need for my respiratory equipment.
My caregiver explained the severity of the immune respiratory, neurological
dysfunction and requested that they call my attorneys [Tom Strong and
Associates of Springfield, Missouri]. My attorneys arranged for me to speak
briefly with Patty Reynolds by phone and allow her to see me through a window.
Although I was suffering from breathing difficultly precipitated by the ordeal
the previous day, I spoke to Patty Reynolds by phone. I described the injury,
the resulting diagnoses, and the need for isolation due to the immune, respiratory,
and neurological degeneration.
Further, I explained that, as the matter was in litigation, I was not free to
comment beyond that I had a number of expert doctors and was receiving
In-Home Care. Patty Reynolds told my caregiver that it would be best if
I were taken to Mount Vernon or some State Facility so that SBU would
not have to pay for the injury.
When I inquired if legal action
would be necessary to halt such endeavors,
she replied that legal action was not necessary, and that she did not intend
(f) If in writing, attach a true copy thereto.
Page 369, 370, and part of 371
To continue to pages Pages 371 -373, click here.