S vs G: Defendants' 1st Interrog

Staddon vs. Griever: Defendants' First Interrogatories to Plaintiffs

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 interrogatories under the provisions of Section 33 of the Georgia Civil Practice Act (O.C.G.A. 9-11-33). You are required to answer these interrogatories separately and fully in writing under oath and to serve a copy of your answers on the undersigned, attorney for Defendant, hereinafter referred to as Defendant within thirty (30) days after service hereof.

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 and description that is or has been in the possession, control, or custody of Plaintiff or of which Plaintiff has knowledge including 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: These interrogatories 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 the trial.

1. List each item of merchandise that was taken from 1242 Hull Road, Athens, GA, by the Plaintiff(s) and/or those assisting him. If these items are no longer in Plaintiffs' possession, state whether or not they have been sold.
2. If the items described in Interrogatory No. 1 have been sold, provide the name, address and telephone number of the persons or entities to which they were sold, and the price and date of each sale.
3. Provide a complete accounting of all sales through vbz.net from 1998 to the present.
4. Identify all persons with personal knowledge of business relationships between you and Defendants.
5. Please state the full name, address and telephone number of every person whom you believe to have any relevant knowledge whatsoever concerning the facts and issues in the above-styled case.
6. Please list and describe, in detail, each and every document, photograph, memorandum, paper, tape recording or other items of physical or material evidence which you may use or have available for public use at the trial of the above-styled case.
7. If recorded statements or any form of written memoranda of the contents of the aforestated persons' interviews were obtained, please describe in detail the nature of said statements, recordings or memoranda, and give the full names, addresses and telephone numbers of any person or persons who have custody, possession, or control of said statements, recordings or memoranda.
8. Identify each person whom you expect to call as an expert witness at trial and state:

   (a) The subject matter on which said expert is expected to testify;

   (b) The substance of the facts and opinions to which the expert is expected to testify and a summary of the ground for each opinion;

   (c) The address, telephone number, education and training of said expert.

9. If there exists any insurance agreement of any type whatsoever under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse you for payments made to satisfy the judgment, state as to all such agreements:

   (a) The name of the insurer;

   (b) The name of the insured;

   (c) The type of insurance;

   (d) The date such agreement was made;

   (e) The policy or other identifying number;

   (f) The amount of the insurer's potential coverage under the agreement; and

   (g) Any conditions on such agreement which you believe may negate or limit the insurer's liability in this case.

10. State all facts concerning any legal proceedings (including claims for workers' compensation) in which you or any member of your immediate family have ever been a party and identify the courts and parties involved.
11. State all facts regarding the bankruptcy of the Plaintiff(s), including court dates and a list of all creditors and the amounts owed to each creditor.
12. Please explain in detail the events surrounding the indefinite leave of absence that Defendant Willard D. Griever has allegedly taken from his online store without consent.
13. Please explain how the images, logos, buttons and graphics appeared on the site and identify the person or persons who performed this work.
14. Please explain how the suppliers were obtained for the store and identify the person or persons who performed this work.
15. Please explain your understanding of why Defendants would continue to provide work to build the store (vbz.net) and the software if an agreement between the participating parties did not exist.

This 13 day of April, 2005.