Griever/2005-03-23 RDA Responds to Interrogatories

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  • Official Title: defendant redistribution alternative inc.'s response to plaintiff's interrogatories
  • This document is in response to "Part 3: Request for Documents to RDA" of Plaintiff's First Requests to RDA.
  • 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.


I hereby serve upon you the following answers of Defendant Redistribution Alternative, Inc. 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 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.



The merchandise tha was purchased to be sold through VBZ.NET has always belonged to 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
  • Jeremy Moore (Mt. Airey, GA)
  • Juliet Easton
  • Scott Pelletier Stephanos
  • John Kisiah (Asheville, NC)


See above.


See documents which are or will be produced by Defendant.


Defendant has no such written or recorded documents.


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






Not applicable.



This 23 day of March, 2005.