Griever/Plaintiff's First Document Requests to Bubba

Staddon vs. Griever: Plaintiffs' 1st Interrog to Bubba

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

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TO: WILLARD DALE GRIEVER, Defendant, or his attorney of record.

Introduction

A. General

1. Interrogatories: You are required, pursuant to O.C.G.A. §9-11-26 and O.C.G.A. §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. §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.
2. 'Production of Documents: You are required, pursuant to OCGA §§ [1] & [2], to produce and permit the plaintiff to inspect and copy the discoverable documents listed below not later than the forty-fifth (45^th) 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^th 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.
3. 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. §24-10-26.

B. Supplementation of Responses

You are required, pursuant to O.C.G.A. §9-11-26 to supplement your responses to these Interrogatories in the following situations:

1. 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;
2. 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;
3. 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.

C. Form of Responses

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.

D. Definitions

1. When asked to "IDENTIFY" some individual, give the following information on each:
   • a) Full name;
   • b) Present home and business address; and
   • c) Occupation and any special area of expertise.
2. "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.
3. "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.

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