Professional Documents
Culture Documents
Plaintiff,
CIVILACfION FILE
vs. NO. 10-7271-4
JILL SHERIDAN
Defendant.
manner below:
GENERAL OBJECTIONS
grounds set forth in paragraphs "A" through "T" below. All general objections
way the scope or effect of any general objection. Plaintiff objects generally to the
Document Requests to the extent they exceed the scope permitted by O.C.G.A. §
9-11-34·
A. Plaintiff objects generally to the Document Requests to the
materiality or any other objections that would require the exclusion of any
testifying in Court.
extent they are not reasonably calculated to lead to the discovery of admissible
evidence.
K. Plaintiff objects generally to the Document Requests to the
extent they seek information that is subject to the attorney-client privilege, work
does not put in issue or constitute the affirmative use of the advice of counselor
and/ or documents shall be returned to Plaintiffs attorneys, along with any copies
made thereof.
nature.
relate to the claims or defenses asserted in this action by any party. Production of
documents that do not relate to the claims and defenses set forth therein shall not
extent they seek to require Plaintiff to produce documents in a form other than as
grounds that the place, date, and time for production specified therein is
all parties.
RESERVATIONS
1. These responses are made without waiver of, and with preservation
of:
any further proceeding in this action (including the trial of this action) or
- (b) The right to object to the use of any such responses, or the -
proceeding;
Ce) The right at any time to revise, correct, add to, supplement
Document Requests, or that the Document Requests are in any way reasonably
response does not mean that Plaintiff in fact has such documents. It means only
that, if Plaintiff has such documents, they will be produced to the extent they are
not privileged. Documents responsive to the Document Requests that are not
the O.C.G.A. at a time and place mutually convenient to the parties, and not
1. Please see attached bill of sale. Plaintiff will provide any additional
2. Please see attached monthly statements and attached bill of sale. Plaintiff
become available.
written contract need exist, as the card issuer does not always require a
Davis v. Discover Bank, 277 Ga. App. 864. Plaintiff further because the
written contract need exist, as the card issuer does not always require a
Davis v. Discover Bank, 277 Ga. App. 864. Plaintiff further because the
become available.
6. Please see attached monthly statements and attached bill of sale. Plaintiff
become available.
to the subject matter or issues of this action, and not reasonably calculated
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
8. Please see attached monthly statements and attached bill of sale. Plaintiff
become available.
9. Please see attached monthly statements and attached bill of sale. Plaintiff
become available.
10. Please see attached monthly statements and attached bill of sale. Plaintiff
become available.
11. Please see attached monthly statements and attached bill of sale. Plaintiff
become available.
12. Plaintiff objects to this Request to the extent that it requires Plaintiff to
to the subject matter or issues of this action, and not reasonably calculated
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
13. Plaintiff objects to this Request to the extent that it requires Plaintiff to
to the subject matter or issues of this action, and not reasonably calculated
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
14. Please see attached monthly statements and attached bill of sale. Plaintiff
become available.
Plaintiff,
CIVIL ACIION FILE
vs. NO. 10-7271-4
JILL SHERIDAN
Defendant.
JILL SHERIDAN
3266 STONEWALL DRIVE
KENNESAW, GA 30152 Av
This JL day of -------,.c---f--1~__t-
Plaintiff,
CMLACfION FILE
VS. NO. 10-7271-4
JILL SHERIDAN
Defendant.
This is to certify that a true and correct copy of the foregoing RULE 5.2
CERTIFICATE was this day served upon the Defendant by depositing the same in
the U.S. Mail affixed with sufficient postage to assure delivery to the following
address:
JILL SHERIDAN
3266 STONEWALL DRIVE
KENNESAW, GA 30152
ThiS~daYOf ~VJ
/
FREDERICK J.
ATIORNE