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This is adapted from The First Set of Interrogatories of Marie O'Hara
(page numbers 371-373, 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 describes the break-in by two Polk County Sheriffs and the
Ms. Patty Reynolds from the Bolivar Office of the Missouri Division of
Aging -- who was shortly afterwards promoted to the head of the Division
of Aging.

This occurred on October 2, 1992 following the failed "break-in" attempt
by the Bolivar Police Chief,
Steve Brown, another Police Officer, and Ms.
Patty Reynolds on the previous day, October 1, 1992 -- which is described
beginning on page 369 of the same First Set of Interrogatories.

The First Set of Interrogatories -   December 20, 1993

Question 31 (Page 371-373)

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 2, 1992

 Set forth the place(s) communication occurred;

       Marie O'Hara's residence.

 Identify each and every person making and receiving each such communication;

      Marie O'Hara, Patty Reynolds, Deputy Wagoner, Deputy Holstance [spelling?],
      my caregiver, and a Lieutenant from the Springfield Police Department.

 Identify each person present when each such communication occurred;

       Marie O'Hara, Patty Reynolds, Deputies, Deputy Wagoner, and Deputy
       Holstance, my caregiver, and a Lieutenant from the Springfield Police

(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;

    The next late afternoon, Patty Reynolds returned with two Sheriff Deputies,
    Deputy Wagoner and Deputy Holstance [spelling?], (without presenting a warrant)
    and proceeded to break in the back door to gain entry to
my isolation room
    in my home.

    As the Sheriffs were forcing
the door I called the Springfield Police Department,
    told them my
name, and the nature of my injuries due to the pesticide poisoning
    at SBU.  

    I asked that the Springfield Police contact my attorneys,
who were not available
    at the time, to prevent my being forcibly
taken to the hospital or State Facility.

    When the Deputies broke
into my isolation room, they demand that I get off
    the phone
(speaker phone), but the Police Lieutenant obtained their names
    before discontinuing the conversation.

    I was interrogated for 45 minutes concerning the names of my expert doctors
    and witnesses, the nature and history of my injury,
and though I was seizuring
    at the time, a pen was forced into my
clenched hand (due to the seizures) and
    I was told to sign her
hand-written document releasing my medical records to
    the Missouri
Division of Aging.

    Patty Reynolds contended that no one else from
SBU got sick and demanded
    the names of my doctors which I gave.

    In addition, they wanted my medical records.  I had to crawl on my
    pulling myself with my arms (due to the incapacity of my legs)
to attempt
    to get

    I was refused access to oxygen when the respiratory seizures
began due
    to the cigarette smoke and other contaminants which
were brought into
    the isolation room.

    As the Deputy indicated that he would return and that if my caregiver
    interfered in any way
she would be arrested.

    When the seizures became continuous, and I could no longer speak,
    they left.

(f)  If in writing, attach a true copy thereto.

Pages 371 -373

To review Pages 369 - 370, click here.