Griever/2005-03-23 Bubba & Lynne Respond to Interrogatories

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  • Official Title: defendants Willard Dale Griever and Norma Lynne Griever's response to plaintiff's interrogatories
  • Submitted to the court on 2005-03-23; received by Plaintiff Nick on 2005-09-30.
  • Links have been added for purposes of cross-reference and clarity; they were not present in the original printed document.
  • Contact information for individuals named in the responses has been omitted from this transcription for reasons of privacy.
  • This document would seem to be in response to the "Interrogatories" section in each of the following documents:


I hereby serve upon you the following answers of Defendants Willard Dale Griever and Norma Lynne Griever to Plaintiffs' First Interrogatories pursuant to O.C.G.A. Section 9-11-33


To the extent that the preamble to the interrogatories of the Plaintiff seeks to impose upon the Defendant any duties or requirements in the excess of those specified by the appropriate provisions of the Georgia Civil Practice Act, the Defendant objects to same. Defendant objects to each of the Plaintiffs' interrogatories to the extent that they seek information regarding communications between Defendant and legal counsel on the grounds that such communications are privileged and are not subject to discovery or seek information regarding materials prepared by or for Defendant or Defendant's representatives in anticipation of litigation or for trial on the grounds that the Plaintiff has not made the required showing for the discovery of such work product material under O.C.G.A. §9-11-26(b)(3) or which seeks information already in the possession of Plaintiff.



Defendants are not in possession of any items of merchandise belonging to Nick Staddon or Red House Media. The merchandise that was purchased to be sold through VBZ.NET has always belonged to RDA. Portions of the merchandise that was initially puchased to be sold in the store has been either taken by the plaintiff, stolen in the burglary of the Red House on 6/09/02, sold in the store, or retained by RDA.


The plaintiff has a record of the items sold through the store and the names and addresses of those who bought the merchandise.


A list of persons familiar with the business relationship of the parties includes but is not limited to:

  • Nick Staddon (Durham, NC)
  • Livia Wade (Athens, GA)
  • Frank Whitehill (Monroe, GA)
  • Jessica Whitehill (Monroe, GA)
  • Cimmeria Griever (Athens, GA)
  • Angela Griever (Athens, GA)
  • Jody Moore (unknown at present)
  • Jeremy Moore (Mt. Airey, GA)
  • Juliet Easton (Hull, GA)
  • Scott Pelletier Stephanos
  • John Kisiah (Asheville, NC)


See above.


See documents which are or will be produced by Defendants.


Defendants have no such written or recorded documents.


As discovery is still ongoing at this early stage of litigation, Defendants have not yet determined who, if anyone, they will call as an expert witness at the trial of this case.




Defendant Lynne Griever was charged with criminal mischief in 1980 after third parties caused property damage to an empty apartment Defendant had vacated. Defendant pled guilty to the charge rather than incur the cost of defense.

Defendant Lynne Griever was arrested for shoplifting in 1981 in Florida and received probation.

Defendants were charged with kidnapping their own children in 1989 or 1990 but were acquitted.


Defendant Willard Dale Griever brought suit against the Coca-Cola company in approximately 1983 for personal injuries sustained as a result of defective packaging of glass bottles.

This 23 day of March, 2005.


By: J. Edward Allen

Georgia State Bar No. 010950
Attorneys for Defendants