Used as Exhibit F in Motion to CompelIN THE STATE COURT OF GWINNETT COUNTY STATE OF GEORGIA MIDLAND FUNDING LLC ASSIGNEE OF CHASE BANK (USA), N.A. Plaintiff, v. JILL SHERIDAN, Defendant EXHIBIT F) ) ) ) ) ) ) ) ) )Civil Action No 10-07271-4DEFENDANT’S SECOND REQUEST FOR INTERROGATORIES, REQUEST FOR ADMISSIONS, AND PRODUCTION OF DOCUMENTS TO PLAINTIFF COMES Now the Defendant JILL SHERIDAN, pro se and requests Midland Funding, LLC to respond appropriately to the defendant’s discovery requests, as the previous responses we
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IN THE STATE COURT OF GWINNETT COUNTY STATE OF GEORGIA MIDLAND FUNDING LLC ASSIGNEE OF CHASE BANK (USA), N.A. ) ) ) Plaintiff, ) ) v. ) Civil Action No ) 10-07271-4 JILL SHERIDAN, ) ) Defendant ) DEFENDANT’S SECOND REQUEST FOR INTERROGATORIES, REQUEST FOR ADMISSIONS, AND PRODUCTION OF DOCUMENTS TO PLAINTIFF COMES Now the Defendant JILL SHERIDAN, pro se and requests Midland Funding, LLC to respond appropriately to the defendant’s discovery requests, as the previous responses were incomplete, evasive, contradictive, and riddled with “boilerplate” objections. Because the Georgia Civil Practice Act considers an evasive or incomplete answer is to be treated as a failure to answer during discovery, the defendant considers these responses as a failure to respond. Each of the discovery responses from the Plaintiff were preceded by a list of “General Objections” and it could only be left to the imagination which of these “General Objections” apply to a specific request. Therefore, one could not
Transcript
IN THE STATE COURT OF GWINNETT COUNTY
STATE OF GEORGIA
MIDLAND FUNDING LLC ASSIGNEE OF CHASE BANK (USA), N.A.
) )
) Plaintiff, )
) v. ) Civil Action No ) 10-07271-4 JILL SHERIDAN, ) )
Defendant )
DEFENDANT’S SECOND REQUEST FOR INTERROGATORIES, REQUEST FOR ADMISSIONS, AND PRODUCTION OF DOCUMENTS
TO PLAINTIFF
COMES Now the Defendant JILL SHERIDAN, pro se and requests Midland
Funding, LLC to respond appropriately to the defendant’s discovery requests, as
the previous responses were incomplete, evasive, contradictive, and riddled with
“boilerplate” objections. Because the Georgia Civil Practice Act considers an
evasive or incomplete answer is to be treated as a failure to answer during
discovery, the defendant considers these responses as a failure to respond.
Each of the discovery responses from the Plaintiff were preceded by a list of
“General Objections” and it could only be left to the imagination which of these
“General Objections” apply to a specific request. Therefore, one could not
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EXHIBIT F
Page 2 of 15
ascertain whether an answer is complete or whether further information or
documents would have been produced had it not been for the objections asserted.
The Defendant propounded sixteen INTERROGATORIES upon the Plaintiff
to which the response included a preamble of eighteen “General Objections”. The
Defendant propounded thirteen PRODUCTION OF DOCUMENTS requests upon
the Plaintiff to which the Plaintiff’s response included twenty “General
Objections”. The Defendant propounded twelve REQUESTS FOR ADMISSION
upon the Plaintiff to which the Plaintiff’s response included twenty one “General
Objections”.
Plaintiff is directed to serve its answers to Defendant’s Interrogatories,
Request for Admissions, and Request for Production of Documents to Defendant
on or before thirty (30) days from the date certified below to the Defendant’s
residence 3266 STONEWALL DR NW, KENNESAW GA 30152. If the plaintiff
cannot fulfill the defendant’s requests for discovery, it is requested by the
defendant that a meet and confer be scheduled to avoid any further waste of time
and resources.
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REMAINING PAGES INTENTIONALLY OMITTED- REQUESTS ARE EXACTLY THE SAME AS EXHIBITS "A" AND "C"
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