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Plaintiff's First Set of Interrogatories to Defendants Ana Gispert, Derek Thomas and Lashanda Adams

Plaintiff's First Set of Interrogatories to Defendants Ana Gispert, Derek Thomas and Lashanda Adams

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Published by cinaripat
United States District Court,Southern District Of Florida,Traian Bujduveanu v. Dismas Charities,Ana Gispert,Derek Thomas and Lashanda Adams,United States District Court,Southern District Of Florida,Traian Bujduveanu v. Dismas Charities,Ana Gispert,Derek Thomas and Lashanda Adams,Mental and Physical Torture at Dismas Charities,Abuse at Dismas Charities,Civil rights Violations at Dismas Charities,Illegal Search And Seizure at Dismas Charities,Discrimination at Dismas Charities,Reverse Discriminarion at Dismas Charities,Abuse at Dismas Charities
United States District Court,Southern District Of Florida,Traian Bujduveanu v. Dismas Charities,Ana Gispert,Derek Thomas and Lashanda Adams,United States District Court,Southern District Of Florida,Traian Bujduveanu v. Dismas Charities,Ana Gispert,Derek Thomas and Lashanda Adams,Mental and Physical Torture at Dismas Charities,Abuse at Dismas Charities,Civil rights Violations at Dismas Charities,Illegal Search And Seizure at Dismas Charities,Discrimination at Dismas Charities,Reverse Discriminarion at Dismas Charities,Abuse at Dismas Charities

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Published by: cinaripat on Aug 26, 2011
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02/02/2013

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 11-20120-CIV-SEITZ/SIMONTONTRAIAN BUJDUVEANU,Plaintiff,vs.DISMAS CHARITIES, INC., ANA GISPERT,DEREK THOMAS and ADAMS LASHANDADefendants. _________________________________________/
PLAINTIFF TRAIAN BUJDUVEANU’S FIRST SET OFINTERROGATORIES TO DEFENDANTS ANA GISPERT, DEREK THOMASAND LASHANDA ADAMS
Plaintiffs, Traian Bujduveanu, Pro Se, pursuant to the Federal Rules of CivilProcedure, propound the following Interrogatories to be answered under oath byDefendants, Dismas Charities,Inc., Ana Gispert, Derek Thomas and Lashanda Adams,within thirty (30) days of service hereof.
INSTRUCTIONS
1. These Interrogatories are continuing in character so as to require you to filesupplementary answers if you obtain further or different information before trial.2. Pursuant to , you are under a duty seasonably to amend any answer to theseinterrogatories for which you learn that the answer is in some material respectincomplete or incorrect and if the additional or corrective information has nototherwise been made known to us during the discovery process or in writing.3. For any interrogatory or part of an interrogatory which you refuse to answer under a claim of privilege, submit a sworn or certified statement from your counsel or oneof your employees in which you identify the nature of the information withheld;specify the grounds of the claimed privilege and the paragraph of these interrogatoriesto which the information is responsive; and identify each person to whom theinformation, or any part thereof, has been disclosed.4. Answer each interrogatory fully. If you object to any interrogatory, state thereasons for objection and answer to the extent the interrogatory is not objectionable. If you are unable to answer an interrogatory fully, submit as much information as is1
 
available, explain why your answer is incomplete, and identify or describe all other sources of more complete or accurate information.5. For any record or document responsive or relating to these interrogatories whichis known to have been destroyed or lost, or is otherwise unavailable, identify eachsuch document by author, addressee, date, number of pages, and subject matter; andexplain in detail the events leading to the destruction or loss, or the reason for theunavailability of such document.6. No agreement, understanding, or stipulation by the Department of Justice or anyof its representatives purporting to modify, limit, or otherwise vary theseinterrogatories shall be valid or binding on the Department of Justice unlessconfirmed or acknowledged in writing (or made of record in open court) by a dulyauthorized representative thereof.7. Unless otherwise stated, these Interrogatories refer to the time, place, andcircumstances of the occurrence mentioned or complained of in the Complaint.8. Where name and identity of a person is required, please state full name, homeaddress and also business address, if known.9. Where knowledge or information in possession of a party is requested, suchrequest includes knowledge of the party's agents, representatives, and unless privileged, his attorneys, and includes knowledge obtained from other persons or sources, even if suchknowledge would be hearsay under applicable law, and even if the person receivingsuch information did not believe it, failed to confirm its validity, disregarded it, or hadother knowledge that cast doubt on the information.10. In the event that any document requested by these interrogatories or to whichyou refer in your answers to these Interrogatories is withheld on the basis of a claimof privilege, set forth for each document withheld:(a) A description of the factual and legal basis for the claim of privilege or objectionin sufficient detail so as to permit the court to determine the validity of the claim or objection;(b) A general description of the document including its size, length, form and subjectmatter;(c) The name and address of the person(s) or entity involved in the creation of thedocument;2
 
(d) The date on which the document was created;(e) The names and addresses of all persons who have had access to the documentfrom the time of its creation to the present;(f) The date on which the document was created; and(g) The name and address of the present custodian of the document, and the namesand addresses of all persons who have received copies, summaries, or explanations of the document.11. In the event that any document to which you refer in your answers to theseInterrogatories has been destroyed or discharged, or has otherwise left your  possession, custody and control, set forth:(a) A general description of the document including its size, length, form and subjectmatter;(f) The date, manner, and reason(s) for destruction or discard; and(g) The names and addresses of persons authorizing and carrying out the destructionor discard of the document.12. These interrogatories are addressed to all Defendants in this case.
DEFINITIONS
1. The word "documents" is used in these Interrogatories in the broad and liberalsense and means written, typed, printed, recorded or graphic matter, however stored, produced or reproduced, of any kind and description and whether an original, master,duplicate or copy, including, but not limited to, papers, notes, accounts, books,advertisements, letters, memoranda, notes of conversations, contracts, agreements,drawings, telegrams, electronic mail, tape recordings, communications, includinginter-office and intra-office memoranda, reports, studies, working papers, corporaterecords, minutes of meetings, notebooks, bank deposit slips, bank checks, cancelledchecks, diaries, diary entries, appointment books, desk calendars, photographs,transcriptions or sound recordings of any type of personal or telephone conversationsor negotiations, meetings or conferences or things similar to any of the foregoing, andto include any data, information or statistics contained within any data storagemodules, tapes, discs, diskettes, or other memory device, or other informationretrievable from any storage systems, including, but not limited to, computer-3

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