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07.12.2010 Defendant's Request for Production of Documents to Plaintiff - Midland v. Sheridan

07.12.2010 Defendant's Request for Production of Documents to Plaintiff - Midland v. Sheridan

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Published by Jillian Sheridan
Defendant's Request for Production of Documents to Plaintiff Court Exhibit A
Defendant's Request for Production of Documents to Plaintiff Court Exhibit A

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Published by: Jillian Sheridan on Dec 11, 2010
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05/24/2011

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 IN THE STATE COURT OF GWINNETT COUNTYSTATE OF GEORGIAMIDLAND FUNDING LLC ASSIGNEEOF CHASE BANK(USA), N.A.)))Plaintiff, ))v. ) Civil Action No) 10-7271-4JILL SHERIDAN,
 pro se
))Defendant )
DEFENDANT’S REQUEST FOR PRODUCTION OF DOCUMENTS
 COMES Now Defendant, JILL SHERIDAN,
 pro se
and files thisDefendant’s Request for Production of Documents pursuant to O.C.G.A. § 9-11-34requesting Plaintiff, Midland Funding LLC, and representing attorney on file,Dennis E. Henry of Frederick J. Hanna & Associates, P.C. to produce thedocuments indicated below for inspection and copying by the Defendant, JillSheridan. You are required to inform Jill Sheridan of the date, place, and time thatJill Sheridan can view and inspect the documents and make copies in the locale of attorney’s office, Marietta, GA. Alternately, you can furnish Jill Sheridan withverified copies of all documents. If the document does not exist, you are requiredto state that it does not exist. Failure to comply fully or partially with this request
EXHIBIT A
 
 
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 within thirty days of receipt of service shall be deemed a confession that thedocument does not exist.You are further requested pursuant to O.C.G.A. § 24-10-26 to produce thesedocuments at any deposition, mediation session, hearing or trial in this case.DEFINITIONSThe following definitions are to be used in responding to the following requests.A. “Plaintiff,” means MIDLAND FUNDING LLC, ASSIGNEE OF CHASEBANK(USA), N.A., or any agent, employee, officer, director, or any other personacting on its behalf.B. “Defendant” means, JILL SHERIDAN an individual.C. “Document” means any written, recorded or graphic matter, whetherproduced, reproduced or stored on papers, cards, tapes, belts, or computer devicesor any other medium in your possession, custody or control, or known by you toexist, and includes originals, all copies of originals, and all prior drafts. It includesall original business records, non-identical copies, computations, memoranda of oral or telephone conversations, tabulations, records of correspondence, notesmade on other documents, microfilms, etc.
 
 
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INSTRUCTIONS
1. This request for production of documents is directed toward allinformation known or available to Plaintiff including information contained in therecords and documents in Plaintiff’s custody or control or available to Plaintiff upon reasonable inquiry.
 
2. A request to identify a document is a request to state as applicable: a)The date of the document; b) The type of document; c) The names and presentaddresses of the person or persons who prepared the document and of the signersand addressers of the document; d) The name of the employer or principal whomthe signers, addressers and preparers were representing; e) The present location of the document; f) The name and current business and home addresses of thepresent custodians of the original document, and any copies of it; g) A summaryof the contents of the document; and h) If the original document was destroyed,the date and reason for or circumstances by which it was destroyed.3. Each request for production of documents is to be deemed a continuingone. If, after serving an answer to any requests for documentation, you obtain orbecome aware of any further information pertaining to that requested production of documents, you are requested to serve a supplemental answer setting forth suchinformation.

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