Griever/Plaintiff's First Document Requests to Bubba - Revision history

Woozle: category updates

2015-08-15T18:00:41Z

category updates

← Older revision		Revision as of 18:00, 15 August 2015
Line 1:		Line 1:
	~~[[Category:~~2005-01-25]]		{{datecat\|2005-01-25}}
	~~{{SvsG Legal Documents\|Plaintiffs' First Document Requests to Bubba}}~~		[[category:Griever]]
			[[category:Griever/legal]]

	*'''Formal title''': Plaintiffs' First Interrogatories, Request for Production of Documents, and Notice to Produce at Trial to Defendant Willard Dale Griever		*'''Formal title''': Plaintiffs' First Interrogatories, Request for Production of Documents, and Notice to Produce at Trial to Defendant Willard Dale Griever

Woozle: Woozle moved page SvsG:Plaintiffs' First Document Requests to Bubba to Griever/Plaintiff's First Document Requests to Bubba: reorganizing

2015-08-15T17:59:42Z

Woozle moved page SvsG:Plaintiffs' First Document Requests to Bubba to Griever/Plaintiff's First Document Requests to Bubba: reorganizing

← Older revision	Revision as of 17:59, 15 August 2015
(No difference)

Woozle: formatting and such

2005-08-22T21:39:54Z

formatting and such

← Older revision		Revision as of 21:39, 22 August 2005
Line 1:		Line 1:
	[[Category:2005-01-25]]		[[Category:2005-01-25]]
	~~[[Staddon vs. Griever]]: [[S vs G: Plaintiffs' 1st Interrog to Bubba~~\| Plaintiffs' ~~1st Interrog~~ to Bubba]]		{{SvsG Legal Documents\|Plaintiffs' First Document Requests to Bubba}}

	*'''Formal title''': Plaintiffs' First Interrogatories, Request for Production of Documents, and Notice to Produce at Trial to Defendant Willard Dale Griever		*'''Formal title''': Plaintiffs' First Interrogatories, Request for Production of Documents, and Notice to Produce at Trial to Defendant Willard Dale Griever
Line 11:		Line 11:
	=Text=		=Text=
	TO: WILLARD DALE GRIEVER, Defendant, or his attorney of record.		TO: WILLARD DALE GRIEVER, Defendant, or his attorney of record.
	==Introduction==		==Part 1: Introduction==
	{{Boilerplate Legal Text: Georgia Document Discovery 1}}		{{Boilerplate Legal Text: Georgia Document Discovery 1}}
	==I. Plaintiff's First Interrogatories to Defendant Willard Dale Griever==		==Part 2: Interrogatories==
			'''I. Plaintiff's First Interrogatories to Defendant Willard Dale Griever'''

	{{Boilerplate Legal Text: SvsG Document Discovery 1}}		{{Boilerplate Legal Text: SvsG Document Discovery 1}}
	==II. and III. Plaintiffs' First Request for the Production of Documents and Notice to Produce at Trial to Defendant Willard Dale Griever==		==Part 3: Requests and Notice==
			'''II. and III. Plaintiffs' First Request for the Production of Documents and Notice to Produce at Trial to Defendant Willard Dale Griever'''

	{{Boilerplate Legal Text: SvsG Document Discovery 2}}		{{Boilerplate Legal Text: SvsG Document Discovery 2}}

	This 25 day of January, 2005.		This 25 day of January, 2005.

Woozle: /* Notes */

2005-07-04T21:42:00Z

Notes

← Older revision		Revision as of 21:42, 4 July 2005
Line 5:		Line 5:
	=Notes=		=Notes=
	*This document is basically all boilerplate text:		*This document is basically all boilerplate text:
	**~~Introduction:~~ [[Template:Boilerplate Legal Text: Georgia Document Discovery 1]]		**[[Template:Boilerplate Legal Text: Georgia Document Discovery 1\|Introduction]]
	**~~Section I.:~~ [[Template:Boilerplate Legal Text: SvsG Document Discovery 1]]		**[[Template:Boilerplate Legal Text: SvsG Document Discovery 1\|Section I]]
	**~~Sections II., III.:~~ [[Template:Boilerplate Legal Text: SvsG Document Discovery 2]]		**[[Template:Boilerplate Legal Text: SvsG Document Discovery 2\|Sections II, III]]

	=Text=		=Text=

Woozle at 21:40, 4 July 2005

2005-07-04T21:40:37Z

← Older revision		Revision as of 21:40, 4 July 2005
Line 4:		Line 4:
	*'''Formal title''': Plaintiffs' First Interrogatories, Request for Production of Documents, and Notice to Produce at Trial to Defendant Willard Dale Griever		*'''Formal title''': Plaintiffs' First Interrogatories, Request for Production of Documents, and Notice to Produce at Trial to Defendant Willard Dale Griever
	=Notes=		=Notes=
	*"Introduction~~" appears to be identical to that in several other documents, so~~ I ~~put it~~ [[Template:Boilerplate Legal Text: ~~Georgia~~ Document Discovery 1~~\|here~~]] ~~and included it from there rather than retyping each time~~.		*This document is basically all boilerplate text:
			**Introduction: [[Template:Boilerplate Legal Text: Georgia Document Discovery 1]]
			**Section I.: [[Template:Boilerplate Legal Text: SvsG Document Discovery 1]]
			**Sections II., III.: [[Template:Boilerplate Legal Text: SvsG Document Discovery 2]]

	=Text=		=Text=
	TO: WILLARD DALE GRIEVER, Defendant, or his attorney of record.		TO: WILLARD DALE GRIEVER, Defendant, or his attorney of record.
	==Introduction==		==Introduction==
	{{Boilerplate Legal Text: Georgia Document Discovery 1}}		{{Boilerplate Legal Text: Georgia Document Discovery 1}}

	==I. Plaintiff's First Interrogatories to Defendant Willard Dale Griever==		==I. Plaintiff's First Interrogatories to Defendant Willard Dale Griever==
	{{Boilerplate Legal Text: SvsG Document Discovery 1}}		{{Boilerplate Legal Text: SvsG Document Discovery 1}}
	==II. and III. Plaintiffs' First Request for the Production of Documents and Notice to Produce at Trial to Defendant Willard Dale Griever==		==II. and III. Plaintiffs' First Request for the Production of Documents and Notice to Produce at Trial to Defendant Willard Dale Griever==
	~~The documents requested to be produced are the following~~:		{{Boilerplate Legal Text: SvsG Document Discovery 2}}
	~~#All invoices, computer-generated documents, which are related to the business of The Redistribution Alternative, Inc.~~
	~~#All income tax returns for the individual and business for the period of time The Redistribution Alternative, Inc. was operated.~~
	~~#All case receipt books or cash receipt documents related to the business.~~
	~~#All documents related to monthly gross sales of the business from the date the business began until the present date.~~
	~~#All documents which show accounting of the sale of merchandise purchased and/or sold on behalf of Red House Media.~~
	~~#All letters, writings, correspondence, documents (as defined herein) reflecting communications between you and Plaintiffs.~~
	~~#All financial statements and accounting records of each Defendant including, without limitation, balance sheets, income and expense statements, statements of net worth from June 20, 1997 to date.~~
	~~#All documents that evidence, refer or relate to the Defendant's contractual relationship with Plaintiffs.~~
	~~#All documents that evidence, refer or relate to the payment of any funds by Defendant to Plaintiff.~~
	~~#All documents identified by Defendant in response to Plaintiffs' First Interrogatories.~~
	~~#All documents consulted, referred to, or otherwise utilized in any way in connection with the preparation of Defendant's responses to Plaintiffs' First Interrogatories.~~
	~~#All correspondence and other documents which evidence, reflect, or relate to any communication between Plaintiffs and Defendant.~~
	~~#All documents which Defendant contends contain relevant information in support of any defense asserted by Defendant in this lawsuit.~~

	This 25 day of January, 2005.		This 25 day of January, 2005.

Woozle at 21:30, 4 July 2005

2005-07-04T21:30:06Z

@@ Line 11: / Line 11: @@
 ==I. Plaintiff's First Interrogatories to Defendant Willard Dale Griever==
-#List each item of merchandise which belongs to Plaintiff Red House Media, which is currently in your possession or control. If these items are no longer in your possession, state whether or not they have been sold.
+{{Boilerplate Legal Text: SvsG Document Discovery 1}}
 ==II. and III. Plaintiffs' First Request for the Production of Documents and Notice to Produce at Trial to Defendant Willard Dale Griever==
 The documents requested to be produced are the following:

Woozle at 21:13, 4 July 2005

2005-07-04T21:13:29Z

← Older revision		Revision as of 21:13, 4 July 2005
Line 3:		Line 3:

	*'''Formal title''': Plaintiffs' First Interrogatories, Request for Production of Documents, and Notice to Produce at Trial to Defendant Willard Dale Griever		*'''Formal title''': Plaintiffs' First Interrogatories, Request for Production of Documents, and Notice to Produce at Trial to Defendant Willard Dale Griever
			=Notes=
			*"Introduction" appears to be identical to that in several other documents, so I put it [[Template:Boilerplate Legal Text: Georgia Document Discovery 1\|here]] and included it from there rather than retyping each time.
	=Text=		=Text=
	TO: WILLARD DALE GRIEVER, Defendant, or his attorney of record.		TO: WILLARD DALE GRIEVER, Defendant, or his attorney of record.

Woozle: /* Introduction */

2005-07-04T21:09:33Z

Introduction

@@ Line 6: / Line 6: @@
 TO: WILLARD DALE GRIEVER, Defendant, or his attorney of record.
 ==Introduction==
-===A. General===
+{{Boilerplate Legal Text: Georgia Document Discovery 1}}
-#'''Interrogatories''': You are required, pursuant to O.C.G.A. &sect;[http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=9-11-26 9-11-26] and O.C.G.A. &sect;[http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=9-11-33 9-11-33], to answer the following Interrogatories separately and fully, in writing and under oath within 45 days of their service on you. You are required by O.C.G.A. &sect;[http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=9-11-33 9-11-33] to answer the Interrogatories by furnishing all discoverable information available to you, which includes information which you have the power to secure and information which is within the knowledge of you or your attorney.
 ==I. Plaintiff's First Interrogatories to Defendant Willard Dale Griever==
 #List each item of merchandise which belongs to Plaintiff Red House Media, which is currently in your possession or control. If these items are no longer in your possession, state whether or not they have been sold.

Woozle: /* D. Definitions */

2005-07-04T20:37:52Z

D. Definitions

@@ Line 19: / Line 19: @@
 ===D. Definitions===
 #When asked to "IDENTIFY" some individual, give the following information on each:
-#*a) Full name;
+#*(a) Full name;
-#*b) Present home and business address; and
+#*(b) Present home and business address; and
-#*c) Occupation and any special area of expertise.
+#*(c) Occupation and any special area of expertise.
 #"IDENTIFY", when referring to a business entity, means to state the entity's complete name, then entity's business address and telephone number and to describe the entity's main business activity.
 #"DOCUMENT", as used herein, a document shall mean any tangible thing upon which information is or has been stored, recorded, or communicated in the custody, control, or possession of Defendant or of which Plaintiff has knowledge, including without limitation, letters, correspondence, invoices, contracts, agreements, purchase orders, memoranda, tapes, stenographic and handwritten notes, microfilm, bulletins, circulars, pamphlets, studies, reports, notices, diaries, summaries, books, messages, instructions, pictures, film, graphs, statistical compilations, magnetic disks, records, and tapes, and other media, computer cards, tapes printouts, reports and other machine-readable records and data, sound recordings, and every draft or copy of a document which is not identical to the original or which draft or copy contains any commentary or notation whatsoever that does not appear on the original.
-{{editing}}
+==I. Plaintiff's First Interrogatories to Defendant Willard Dale Griever==

Woozle at 20:17, 4 July 2005

2005-07-04T20:17:47Z

← Older revision		Revision as of 20:17, 4 July 2005
Line 2:		Line 2:
	[[Staddon vs. Griever]]: [[S vs G: Plaintiffs' 1st Interrog to Bubba\| Plaintiffs' 1st Interrog to Bubba]]		[[Staddon vs. Griever]]: [[S vs G: Plaintiffs' 1st Interrog to Bubba\| Plaintiffs' 1st Interrog to Bubba]]

	*'''Formal title''': Plaintiffs' Request for ~~Admission~~ of ~~Facts~~ to Defendant Willard Dale Griever		*'''Formal title''': Plaintiffs' First Interrogatories, Request for Production of Documents, and Notice to Produce at Trial to Defendant Willard Dale Griever
	*Bubba's answers are in [[S vs G: Bubba's Answers to Admission Request\| Bubba's Answers to Admission Request]], and I have retroactively included them below <span class=hilite>with highlighting</span> for ease of reference.
	=Text=		=Text=
	~~NOW COME PLAINTIFFS NICK STADDON and COX-STADDON ENTERPRISES~~, ~~INC~~. d/b/~~a RED HOUSE MEDIA and d~~/b/~~a vbz~~.~~net ("Plaintiffs")~~ and ~~request pursuant to~~ O.C.G.A. §[http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=9-11-36 9-11-36]~~(a) that DEFENDANT WILLARD DALE GRIEVER ("Defendant") admit~~ the ~~matters set forth below~~, ~~or deny same~~ in writing, within ~~forty-five (~~45) days ~~from the date~~ of service ~~hereof~~.		TO: WILLARD DALE GRIEVER, Defendant, or his attorney of record.
			==Introduction==
	~~Defendant is~~ required to ~~admit that:~~		===A. General===
			#'''Interrogatories''': You are required, pursuant to O.C.G.A. §[http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=9-11-26 9-11-26] and O.C.G.A. §[http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=9-11-33 9-11-33], to answer the following Interrogatories separately and fully, in writing and under oath within 45 days of their service on you. You are required by O.C.G.A. §[http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=9-11-33 9-11-33] to answer the Interrogatories by furnishing all discoverable information available to you, which includes information which you have the power to secure and information which is within the knowledge of you or your attorney.
	#~~Willard Dale Griever rented Plaintiff Nick Staddon~~'~~s 1982 Mercedes Benz~~ (~~"Benz")~~		#'''Production of Documents'': You are required, pursuant to OCGA §§ [http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=9-11-26] & [http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=9-11-34], to produce and permit the plaintiff to inspect and copy the discoverable documents listed below not later than the forty-fifth (45<sup>th</sup>) day following service at the offices of Plaintiff's attorney, Cynthia E. Call, 191 Broad Street, Suite 303, Athens, Georgia 30601. If the said 45<sup>th</sup> day falls on the week=end, you are required to make the referenced production at 9:00 a.m. in the offices of the Plaintiff's attorney on the Monday following this weekend. ''As an alternative to so producing the documents at the offices of the Plaintiff's attorney, you may attach copies of the documents to your Interrogatory Answers.''
	#*<~~span class=hilite~~>~~Defendant denies~~ the ~~allegations contained in Paragraph 1~~.</~~span~~>		#'''Notice to Produce at Trial''': You are hereby notified to produce at the time of any hearing, trial, the taking of any deposition of Defendant, in the above-styled case, the documents listed below, which are in your possession, custody, control, the same to be used as evidence by Plaintiffs pursuant to O.C.G.A. §[http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=24-10-26 24-10-26].
	~~#Willard Dale Griever rented~~ the ~~1982 Mercedes Benz belonging~~ to Plaintiff ~~Nick Staddon~~ on ~~a week-~~to~~-week basis~~.		===B. Supplementation of Responses===
	#*<span class=hilite>Defendant ~~denies~~ the ~~allegations contained~~ in ~~Paragraph 2.</span>~~		You are required, pursuant to O.C.G.A. §[http://www.legis.state.ga.us/cgi-bin/gl_codes_detail.pl?code=9-11-26 9-11-26] to supplement your responses to these Interrogatories in the following situations:
	~~#Willard Dale Griever began renting~~ the ~~1982 Mercedes Benz belonging~~ to ~~Plaintiff Nick Staddon on [~~[:~~Category:2001~~-10-~~27\|October 27, 2001]~~].		#Whenever you learn the identity of a person whose name has not been previously disclosed by you and who has knowledge of information relevant to this suit;
	~~#*<span class~~=~~hilite>Defendant denies the allegations contained in Paragraph 3~~.~~</span>~~		#Whenever you learn the name of an expert witness or any witness whose name has not previously been disclosed and who is expected to testify in this suit; in this situation, you must disclose both the expert's name and the subject matter on which he/she is expected to testify;
	~~#Willard Dale Griever had possession of the 1982 Mercedes Benz belonging~~ to ~~Plaintiff Nick Staddon until [~~[:~~Category:2004~~-01-09~~\|January 9, 2004~~]].		#Whenever, after filing your responses to these interrogatories, you learn that your response was incorrectly made, or learn that your response though correct when made, is no longer true, and the circumstances are such that a failure to amend the response is, in substance, a knowing concealment.
	#*<span class=hilite>Defendant denies the ~~allegations contained~~ in ~~Paragraph 4.<~~/~~span>~~		===C. Form of Responses===
	#~~Willard Dale Griever agreed~~ to ~~pay $100~~.~~00 per week for rental~~ of the ~~1982 Mercedes Benz belonging~~ to ~~Plaintiff Nick Staddon~~.		In order to make your responses clear to the court, please number each response to correspond to the particular Interrogatory or request for admission being answered.
	#*~~<span class=hilite>Defendant denies~~ the ~~allegations contained in Paragraph 5~~.~~</span>~~		===D. Definitions===
			#When asked to "IDENTIFY" some individual, give the following information on each:
	~~This 25 day~~ of ~~January~~, ~~2005~~.		#*a) Full name;
			#*b) Present home and business address; and
			#*c) Occupation and any special area of expertise.
			#"IDENTIFY", when referring to a business entity, means to state the entity's complete name, then entity's business address and telephone number and to describe the entity's main business activity.
			#"DOCUMENT", as used herein, a document shall mean any tangible thing upon which information is or has been stored, recorded, or communicated in the custody, control, or possession of Defendant or of which Plaintiff has knowledge, including without limitation, letters, correspondence, invoices, contracts, agreements, purchase orders, memoranda, tapes, stenographic and handwritten notes, microfilm, bulletins, circulars, pamphlets, studies, reports, notices, diaries, summaries, books, messages, instructions, pictures, film, graphs, statistical compilations, magnetic disks, records, and tapes, and other media, computer cards, tapes printouts, reports and other machine-readable records and data, sound recordings, and every draft or copy of a document which is not identical to the original or which draft or copy contains any commentary or notation whatsoever that does not appear on the original.
			{{editing}}