UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP79M00467A000300120031-2
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 9
• Document Creation Date: December 14, 2016
• Document Release Date: June 18, 2003
• Sequence Number: 31
• Publication Date: February 13, 1976
• Content Type: COURTFILE

7r, yid, t
Approved Fo1elease 2003/06/24: CIA-RDP79M004 000300120031, ~
FOR THE DISTRICT OF COLUMBIA
UNITED STATES DISTRICT COURT
ORLANDO NUNEZ DE VILLAVICENCIO,
Y DEL TORO, et al.,
V. ) C. A. No. 75-1863
Plaintiffs,
UNITED STATES OF AMERICA,
et al.,
To: William E. Colby
c/o Jonathan B. Smith,--Esquire
U. S. Department of Justice
Washington, D. C. 20530
INTERROGATORIES
I. DEFINITIONS
The term "document" or "documents" as used in these interroga-
tories includes, without limitation, whether original, copy or
draft, each of the following: contracts, agreements, memoranda,
assignments, licenses,--minutes-.of meetings;- minute books, books-.-
of account, orders, invoices, statements, computation sheets,
notebooks,- reports, medical prescriptions,"_communications.of
any kind (except oral), letters, notes (in pencil, ink or.type-
written), notes or" records of.;oral: communicatioins,~..instructionsf-
telegrams, and other messages, and writings and printed material
of every kind, whether or not the document is privileged or,
within defendant's possession-, custody or control.
In response to a request for identification of a document,
furnish .the . following:.". (a) . the .name and date.of the. document;
(b) the name and address-of the-person originating.the document;
(c) the name and address of the person,. if. any., ..:to whom-the-docu-
ment was addressed; (d) the names and addresses of all persons
to whom copies of the document were to be, or have been, sent;
Approved For Release 2003/06/24: CIA-RDP79M00467A00030012003172
 Approved Fo.lease 2003/06/24: CIA-RDP79M004 000300120031-2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ORLANDO NUNEZ DE VILLAVICENCIO,
Y DEL TORO, et al.,
plaintiffs,
UNITED STATES OF AMERICA,
et al.,
C. A. No. 75-1863
PLAINTIFFS' FIRST SET OF INTERROGATORIES
To: The Central Intelligence Agency
c/o Jonathan B. Smith, Esquire
U. S. Department of Justice
Washington, D. C. 20530
I. DEFINITIONS
The term "document" or "documents" as used in these interroga
tories includes, without limitation, whether original, copy or
draft, each of the following:- contracts, agreements., - -memoranda,:
assignments, licenses, minutes of meetings, minute books, books
of "account,---orders,-invoices, statements,.-,computation-sheets-
notebooks, reports, medical prescriptions,-communications of-
any kind (except oral), letters, notes= (in - pencil-; _ ink or. type
written), notes or records of oral communications, instructions,
telegrams,_and other messages, and writings and printed material-
of every kind, whether or not the document is -privileged- -or-=
within defendant's possession, custody or control.
In response-to a request for identification-of a document,--.
furnish the following: (a) the name and date of the document;
(b) the name and address of the person originating-.thedocument,
(c) the name and address of the person, if any,to whom the docu-
ment was addressed; (d) the names and addresses of all persons
to whom copies of the document were to be, or have been, sent;
Approved For Release 2003/06/24: CIA-RDP79M00467A000300120031-2
 Approved Fo,lease 2003/06/24: CIA-RDP79M004?000300120031-2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ORLANDO NUNEZ DE VILLAVICENCIO,
Y DEL TORO, et al.,
Plaintiffs,
UNITED STATES OF AMERICA,
et al.,
No. 75-1863
PLAINTIFFS' FIRST SET OF INTERROGATORIES
To: The Attorney General of the United States
c/o Jonathan B. Smith, Esquire
U. S. Department of Justice
Washington, D. C. 20530
The term "document" or "documents" as used in these'-
tories includes, without limitation, whether original,
draft, ;. each of. the. following: contracts, agreements, `Man os
assignments, licenses, minutes of meetings, minute books,boo
of account, orders, invoices, statements, computation sheets,
notebooks, reports, medical prescriptions, cormnucicat.ione of
any kind (except oral) , letters, notes (in pencil,-.- ink or
written), notes or records of oral communications, io.troetto s
telegrams, and other messages, and writings and printed ssaterlai`
of every kind, whether or not the document is privileged or
within defendant's: possession-,.-custody or control.-
In response to a request for identification of a document,
furnish the. following: (a) the name and date of the document;.-
(b) the name and address of the person originating the document;
(c) the name and address of the person, if any, to whom-the docu-
ment was addressed; (d) the names and addresses of all-persons-
to whom copies of the document were to be, or have been, sent;..
Approved For Release 2003/06/24: CIA-RDP79M00467A000300120031-2
 Approved Fo,lease 2003/06/24: CIA-RDP79M004 000300120031-2
-2-
(e) the firm or firms with which all such persons were connected
at the date of the document; (f) whether the defendant has
possession, custody or control of the original document or a copy
thereof; (g) and if the defendant is not in possession, custody
or control of the original-or a copy, the name and address of
the person having possession, custody or control of the original
or a copy of the document; and (h) the occasion for and/or
circumstances under which the document was prepared.
The term "person" or "persons" as.-used in-these interrogators
includes, without limitation, any individual, association,
partnership,-corporation, firm or organization.
The term-"client(s)" as used in these interrogatories-include
without limitation, any individual, association, partnership,- -
corporation, firm-or organization, -domestic -or --foreign
Where an interrogatory. requests_.the.identification o
person(s) or client(s), state the full-name, title and present
address,... or. if unknown, .the.--last known.address, - of each. such.
person(s) or client(s).
Where an interrogatory-requests
the identification,-listing.
.or description of an act or event, the following information.
as to each such act or event shall be included wherever.applicabl
ace; _ !c1-=-i dent-i-f-icat-ion of each person--present:
) date ? -(b)
a
p
and the name of the organization each represented or was
connected with;. and.(d) what was said and/or done by each-person.
Any document or other material required to be identified
in response to these interrogatories which defendant-believes.__.
.protected by the attorney-client or other privilege shall be
listed and identified with-the appropriate explanation as-to the-
privilege being claimed.
Approved For Release 2003/06/24: CIA-RDP79M00467A000300120031-2
 Approved For Release 2003/06/24: CIA-RDP79M0046TA000300120031-2
-3-
II. INTERROGATORIES
1. Is the break-in described in plaintiffs' Petition the
same break-in referred to in the report to the President by the
Commission on CIA activities within the United States. submitted
on June 6, 1975 and in.particular, referred to on page 238 of that
report
2.
to the
States
in the fourth complete paragraph on that page?
Please list all documents that were made available
Rockefeller Commission on CIA activities within the United
concerning the plaintiffs and their activities.
.3 List the names of all CIA personnel who presented infor-
within the United
4. List all CIA.. employees who had knowledge or who approved
mation to the Commission on CIA activities
States concerning the plaintiffs.
of the Roland-Studios break-in.-
5. List all-other Government agencies.-who were informed that.
this break-in was to take place or who-were-subsequently notified
6. What-was the length of time'and dates-,of-the surveillance-
of the plaintiffs and.-their activities?
7. What was the exact day and time that the break-in of the
of this..break-in.._
9. Was Orlando Nunez ever employed or did he ever act on
visited plaintiffs in either asocial or official capacity..
8. Li"st alb 'CI--A- employees- who -visited- plaintiffs= before_-=the:
break-in occurred. .This list is to contain all CIA employees. who
Roland Studios took place during 1971?
behalf of the CIA at the Agency's request or--.as a contract-
10. Was Mr. Christopher Fitzgerald present at-the time of-
the February, 1971 break-in?
employee?
Approved For Release 2003/06/24: CIA-RDP79M00467A000300120031-2
 lease 2003/06/24: CIA-RDP79M004,000300120031-2
Approved FO
W
-4-
1,1. List all CIA employees who participated in the actual
break-in.
12. List all CIA employees who entered the Roland Studios
at the time of the break-in.
13. List all employees who were near the break-in scene but
did not enter the premises.
.14. List all CIA employees who kept the plaintiffs under
surveillance before and during the break-in.'
15. List all CIA employees who were involved with the sur
veillance of the-plaintiffs from the Friendship Grill.
16. List all CIA employees who were with the Corporal Robert
Fleck of-the Fairfax City Police Department. in. a_ marked Fairfax-
City Police car at Mundy?s Esso station during the time of the
break-in.
17. List all officials of the Fairfax City Police Department
who were either informed in advance of the Roland Studios break-i
or had -knowledge---of "-same
18. List all members of the Fairfax City Police Department-
whose assistance was requested by the CIA-in executing-the break-:
19. List all Fairfax City officials who were informed of
the break-in..either_ before or after it occurred by the CIA.
20. List all Fairfax City Police o f cia~Is~whose assistance
was requested in the surveillance from Friendship Grill.
-21. List all times and places of surveillance of the pla.in.A_
.tiffs by the-CIA.--
22. List all the times and places of surveillance,by the_.
Fairfax Police Department which were furnished to the CIA.
23. Did William E. Colby have advance notice that the break-
in would take place?
24. Did Richard M. Helms have advance notice that the break-
in would-take place?
Approved For Release 2003/06/24: CIA-RDP79M00467A0003001200311-2
 Approved Po lease 2003/06/24: CIA-RDP79M004S000300120031-2
-5-
25. Does the CIA have any knowledge of any electronic
surveillance either by the CIA, the Fairfax City Police Depart
ment, or any other source of the plaintiffs'. photo studio or
place of residence or electronic surveillance of plaintiffs in-.
any other surroundings whatsoever?
26. In any instance, does the CIA have knowledge of the
opening or inspection of the postal mail of the plaintiffs?
27. Did the CIA request Internal Revenue Service to make
available tax returns of the plaintiffs for CIA inspection?
28. Did the CIA in any instance request information from any
bank where-plaintiffs and/or Roland Studios had bank accounts?
29. Describe the role of Chaos in the break-in or evidence
surrounding it.or the surveillance of the plaintiff.
30. Did the CIA make any attempt to obtain a search warrant-
for the purpose of entering plaintiffs' premises?
31. List each. and every'break-in,along with the time and
place,of the Roland Studios or the residence of either plaintiff.
32. List each- incident,-. time and place where plaintiffs".---.-
telephone conversations were recorded.
33. List each incident, time and place that electronic
surveillance was used concerning the plaintiffs.
1826 Jefferson Place, N. W.
Washington, D. C. 20036
785-1588
Attorneys for Plaintiffs
Approved For Release 2003/06/24: CIA-RDP79M00467A000300120031-2
 Approved Fo,lease 2003/06/24: CIA-ROP79M004,000300120031-2
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Interrogatories
were mailed, postage prepaid, to the following counsel on the
J day of February, 1976.
Fly Hurwitz
Office of the Director
Central Intelligence Agency
Washington, D. C..20505
Attorney General's Office of the
United States--
Constitution Ave. between 9th & 10th Streets, N. W.
Washington, D. C.
Jonathan B. Smith, Esquire
U. S. Department of Justice
Washington, D. C. 20530
Approved For Release 2003/06/24: CIA-RDP79M00467A000300120031-2
 UNCLASSIFIED ~:.;{ ,CONFIDENTIAL j n' SECRET
EXECUTIVE SECRETABIA
outing= Slip
k1PiYG
r~ Y
S/,MER'
." DDS&,r
DDQ
D/ DQ/ICI-.
D/ DQ/NI?
GCS
Coin
D/Perk
D/S
Aut/ Da..
AO/ Da