Griever/2005-03-23 Bubba & Lynne Respond to Document Requests

Staddon vs. Griever: Bubba & Lynne Respond to Document Requests

Notes

• Official Title: defendants Willard Dale Griever and Norma Lynne Griever'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.
• Links have been added for purposes of cross-reference and clarity; they were not present in the original printed document.

Nick Notes

• I do not seem to have the document to which this document responds, or at least it's not obvious at first glance. I will look again more carefully when I am done transcribing.

Contents

Defendants Willard Dale Griever and Norma Lynne Griever respond 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' interrogatories to the extent that they seek information regarding communications 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. §Template:OCGA code(b)(3) or which seeks information already in the possession of Plaintiff.

Responses

1.

Defendants are in the 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 based on their earnings.

3.

None in Defendants' possession. Plaintiff is in possession of documents responsive to this request.

4.

None in Defendants' possession. Plaintiff is in possession of documents responsive to this request.

5.

Editing is currently in progress on this article. Although editing is incomplete, the author or editor has saved their work to prevent loss. Please check back later by reloading the page, and do not edit while this message is still showing. Thank you.