S vs G: Defendants' 1st Request

Staddon vs. Griever: Defendants' First Request for Production of Documents and Notice to Produce at Trial

In the State Court of Athens-Clarke County, State of Georgia

Civil Action #ST-05-CV-0049

Main Text

Defendants herewith serve upon you the following request for production of documents under the provisions of Sec. 34 of the Georgia Civil Practice Act (O.C.G.A. 9-11-34).

You are requested to produce the documents, records, and photographs hereinafter set forth at 11:00 A.M. on the 30th day after service of this request at the office of Fortson, Bentley and Griffin, P.A., 440 College Avenue North, Suite 220, Athens, Georgia 30601.

NOTE A: When used herein the term "Plaintiff" or "you", or any synonym thereof, is intended to and shall embrace and include, in addition to said Plaintiff, counsel for Plaintiff and all agents, servants, employees, representatives, private investigators and others who are in possession of, or may have obtained, information for or on behalf of Plaintiff.

As used herein, "document shall mean but without limitation: every writing or record of every type or description that is or has been in the possession, control or custody of Plaintiff or of which Plaintiff has knowledge without limitation: correspondence, memoranda, tapes, stenographic or handwritten notes, studies, publications, books, pamphlets, pictures, films, voice recordings, maps, graphs, reports, surveys, minutes or statistical compilations; every copy of such writing or record where the original is not in the possession, custody, control of Plaintiff; and every copy of every such writing or record where such copy is not an identical copy of the original or where such copy contains any commentary or notation that does not appear on the original.

As used herein "person" shall mean an individual, firm, partnership, corporation, proprietorship, association, governmental body or any other organization or entity.

NOTE B: This Request for Production shall be deemed continuing and supplemental answers shall be required if the Plaintiff, directly or indirectly, obtains further information of the nature sought herein between the time answers are served and the time of trial.

Plaintiff has possession, custody, or control of each of the following documents and photographs, each of which constitutes or contains information relating to this action within the scope of Sec. 26 of the Georgia Civil Practice Act (O.C.G.A. 9-11-26).

You are requested to produce for inspection and copying each of the following documents and records:

1. All invoices, computer-generated documents (or hand-written) which relate to the business of Red House Media / Cox-Staddon Enterprises, Inc. and/or vbz.net.
2. All income tax returns filed by or on behalf of Plaintiff(s), personal and business, for the period of time beginning 1994 to present.
3. All case receipt books or cash receipt documents related to business.
4. All documents sent to city or county tax boards, assessors or related agencies relating to business beginning 1994 to present.
5. Produce all records that document or identify The ReDistribution Alternative, Inc. as the owner of the merchandise related to vbz.net for the purpose of showing that it would not be the responsibility of the Plaintiff(s) or businesses owned by Nick Staddon, to pay taxes on aforementioned merchandise or for any other purpose.
6. All documents related to monthly gross sales of the business from the date the business began until the present time.
7. All documents which show accounting of the sale of merchandise purchased and/or sold relating to Red House Media and vbz.net.
8. All letters, writings, correspondence, documents (as defined herein) reflecting communications between the parties.
9. All financial statements and accounting records of each Defendant including, without limitation, balance sheets, income and expense statements, statements of net worth from October 1, 1995 to date.
10. All documents that evidence, refer to or relate to the Defendants' contractual relationship with Plaintiff(s) or any Defendant.
11. Documentation of all monies that you contend Defendants have owed or still owe the Plaintiff(s).
12. All documentation of all monies paid to the Plaintiff(s) by Defendants since October of 1995.
13. All documents identified by the Plaintiff(s) in response to the First Interrogatories.
14. All documents consulted, referred to, or otherwise utilized in any way in connection with the preparation of your responses to Defendants' First Interrogatories.
15. All correspondence and other documents which evidence, reflect, or relate to any communication between the parties.

This 13th day of April, 2005.