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08.11.2010 Plaintiff's Response to Defendant's Request for Production of Documents - Midland v Sheridan

08.11.2010 Plaintiff's Response to Defendant's Request for Production of Documents - Midland v Sheridan

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Published by Jillian Sheridan
JILL SHERIDAN http://www.jilliansheridan.com

IN THE STATE COURT OF GWINNETT COUNlY STATE OF GEORGIA

EXHIBIT B

MIDLAND FUNDING LLC, ASSIGNEE OF CHASE BANK (USA), N.A.,

Plaintiff,
vs. JILL SHERIDAN CIVILACfION FILE NO. 10-7271-4

Defendant.

RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCfION OF DOCUMENTS
COMES NOW Plaintiff, by and through counsel, and responds to Defendants' Request for Production of Documents, as set forth in the following manner below: GENERAL OBJECTIONS Plaintiff generally objects and responds to the Document Requests on
JILL SHERIDAN http://www.jilliansheridan.com

IN THE STATE COURT OF GWINNETT COUNlY STATE OF GEORGIA

EXHIBIT B

MIDLAND FUNDING LLC, ASSIGNEE OF CHASE BANK (USA), N.A.,

Plaintiff,
vs. JILL SHERIDAN CIVILACfION FILE NO. 10-7271-4

Defendant.

RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCfION OF DOCUMENTS
COMES NOW Plaintiff, by and through counsel, and responds to Defendants' Request for Production of Documents, as set forth in the following manner below: GENERAL OBJECTIONS Plaintiff generally objects and responds to the Document Requests on

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Published by: Jillian Sheridan on Dec 11, 2010
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01/13/2013

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IN
THE
STATE COURT OF GWINNETT COUNlYSTATE OF GEORGIAMIDLAND FUNDING
LLC,
ASSIGNEE OF CHASE
BANK
(USA),N.A.,
Plaintiff,
vs.JILL SHERIDAN
Defendant.
CIVILACfION FILE
NO.
10-7271-4
RESPONSE TO
DEFENDANT'S REQUEST
FOR PRODUCfION
OFDOCUMENTS
COMES NOW Plaintiff,
by
and through
counsel,
and
responds
to
Defendants'
Request
for
Production of
Documents, as
set
forth in
the
following
manner
below:GENERAL OBJECTIONSPlaintiff generally objects
and
responds
to
the
Document
Requests on
the
groundsset
forth
in paragraphs
"A"
through "T" below. All general objectionsshall
be
deemed
to be
continuing
and
shall
be
construed
as supplementing
eachspecific objection
and/or
response
to the
Document Requests. No specificobjection
and
no
response
contained
herein shall be
interpreted
as limiting in anyway
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·
EXHIBIT B
 
A.
Plaintiff objects generally to the Document Requests to theextent they exceed
the
scope permitted by
O.C.G.A.
§
9-11-34.
B.
Each response
is
subject to all objections as to relevance andmateriality or any other objections that would require the exclusion of anystatement herein if such statement were to be made
by
a witness present andtestifying in Court.
C.
A response to any Document Request is not intended andshould not be construed to be a waiver by Plaintiff of
all
or any part of anyobjection to any Document Request.
D.
Plaintiff objects generally to the Document Requests to theextent they assume facts that are inaccurate.
E.
Plaintiff objects generally to the Document Requests to theextent they are argumentative.
F.
Plaintiff objects generally to the Document Requests to theextent they are defective in
forIfi.
G.
Plaintiff objects generally to the Document Requests to theextent they are overly broad.
H.
Plaintiff objects generally to the Document Requests to theextent they are unduly burdensome.
1.
Plaintiff objects generally to the Document Requests to theextent they are oppressive.
J.
Plaintiff objects generally to the Document Requests to theextent they are not reasonably calculated to lead to the discovery of admissibleevidence.
 
K.
Plaintiff objects generally to the Document Requests to
the
extent they impose on it an unreasonable burden of inquiry.
L.
Plaintiff objects generally to the Document Requests to theextent they seek information that
is
subject to the attorney-client privilege, workproduct privilege, or any other privilege or legal protection. The inadvertent ormistaken production of information
and/
or documents subject
to the
protections
of
the attorney-client privilege, work product privilege, or any other privilege orlegal protection shall not constitute a general, inadvertent, implicit, subjectmatter, separate, independent, or other waiver of such privilege
or
protection anddoes not
put
in issue or constitute the affirmative use of the advice of counselor
of
any privileged communications.
All
such inadvertently produced information
and/
or documents shall be returned to Plaintiffs attorneys, along with any copiesmade thereof.
M.
Plaintiff objects generally to the Document Requests to theextent they seek information that
is
of a confidential, proprietary,
or
trade secretnature.
N.
Plaintiff objects generally to the Document Requests to
the
extent they seek information
that
was prepared in anticipation
of
litigation.
O.
Plaintiff objects generally to the Document Requests to theextent they are not properly limited as to time.
P.
Plaintiff objects generally to the Document Requests to
the
extent they seek documents not in its possession, custody, or control.
Q.
Plaintiff reserves its right to supplement its objections
and
responses to the Document Requests to the extent necessary
and
appropriate.

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