Page:Touhy v. Walgreen Company.pdf/6

 In her deposition, Ms. Whitlock admitted that she knew Mr. Abrams and that she was friends with Ms. Frazier. Ms. Whitlock also admitted that, as a pharmacy technician for Walgreen, she could have accessed Ms. Touhy's prescription information so long as she had Ms. Touhy's name and area code. Ms. Whitlock insisted, however, that she never accessed Ms. Touhy's records and never revealed such information to Ms. Frazier, Mr. Abrams, or anyone else.

Ms. Touhy also issued various interrogatories and document requests seeking evidence to substantiate her hypothesis about Ms. Whitlock's involvement. Among these requests, a handful still remain the subject of dispute at this advanced stage in the proceedings. They include Ms. Touhy's request for "log files" or other documents capable of identifying which employees had accessed Ms. Touhy's pharmacy account information (Doc. Requests 10-12). They also include a request that Walgreen "[i]dentify each person(s) who have assisted in the designing, maintenance and/or operation of any computer system that houses Plaintiff's records" (Interrog. 10), as well as a request for the production of "all manuals concerning any computer system or program” that housed information about Ms. Touhy (Doc. Request 14). The challenged requests further include Ms. Touhy's demand for production of: Ms. Whitlock's personnel file (Doc. Request 4); "all communications between [Walgreen] and Whitlock" (Doc. Request 8); all email from Ms. Whitlock's corporate email account (Doc. Request 9); and "all documents. . . that relate in any way to Plaintiff, Whitlock or -6-