SvsG:2005-03-23 RDA Responds to Document Requests
Staddon vs. Griever: RDA Responds to Document Requests
Notes
- Official Title: defendant redistribution alternative's response to plaintiff's request for production of documents
- Submitted to the court on 2005-03-23; received by Plaintiff Nick on 2005-09-30.
- This document is in response to "Part 2: Interrogatories to RDA" of Plaintiffs' First Requests to RDA.
- 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.
Contents
Redistribution Alternative, Inc. responds to Plaintiffs' Request for Production of Documents as follows:
OBJECTION TO PREAMBLE
To the extent that the Request for Production of Documents 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' requests to the extent that they seek information regarding communication between Defendant and Defendant's 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.
Responses
1.
Defendants are in possession of some invoices which will be produced at such time as they may be located. Plaintiff is in possession of other documents responsive to this request.
2.
[Defendants] are not required to file income tax returns. (Editor's note: original says "Defendant is are...")
3.
Plaintiff is in possession of documents responsive to this request.
4.
Defendants are in possession of a partial database of information. Plaintiff is in possession of documents responsive to this request.
5.
Defendants are in possession of a high number of email communications which will be produced at such time as they may be converted from computer files to other media.
6.
Documents responsive to this request, if any, will be produced as they are located by Defendant.
7.
None.
8.
Defendants will produce any cancelled checks in their possession at such time as the same can be located.
9.
None other than as described herein.
10.
None other than as described herein.
11.
None other than as described herein.
12.
None other than as described herein.
This 23 day of March, 2005
FORTSON, BENTLEY AND GRIFFIN, P.A.
By: J. Edward Allen
- Georgia State Bar No. 010950
- Attorneys for Defendants