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IN THE SUPERIOR COURT OF DEKALB COUNTY

STATE OF GEORGIA
KAREN HELBLING,

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) Civil Action
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) Case No.: ___________________
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)
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Plaintiff,
vs.
ABIGAIL PARSONS,
Defendant.

DEFENDANTS RESPONSES TO PLAINTIFFS FIRST CONTINUING


INTERROGATORIES TO DEFENDANT
COMES NOW, Abigail Parsons (hereafter referred to as Defendant), Defendant in the
above-styled action, and responds to Plaintiffs First Continuing Interrogatories to Defendant
(hereinafter Interrogatories) as follows:

GENERAL OBJECTIONS
Defendant objects to the preamble of Plaintiffs Interrogatories to the extent that it calls
for Defendant to provide information not required by the Rules of Civil Discovery as set forth in
O.C.G.A. 9-11-26 et seq. Defendant also does not agree to be bound by any definitions set out
by the Plaintiff. Rather, in responding to these interrogatories, Defendant will give words their
ordinary meaning and usage. Defendant will comply only with the provisions of applicable law
in responding to these interrogatories and does not agree to be bound by any restrictions or
instructions set out by the Plaintiff.
Defendant objects to Plaintiffs Interrogatories as a whole to the extent that they conflict
with or seek to expand upon Defendants discovery obligations under the Georgia Civil Practice
Act. In addition, Plaintiff objects to Plaintiffs Interrogatories to the extent that they seek
information regarding Defendants attorneys legal theories, opinions, defense strategies, work

product, other information regarding Plaintiffs attorneys legal theories, opinions, defense
strategies, work product, other information prepared specifically in anticipation of litigation, and
or seek discovery of attorney / client communications. Subject to these objections, and without
waiving same, Defendant responds to Plaintiffs Interrogatories as follows:
INTERROGATORIES
1.
EXPERT WITNESSES
Please identify any person that you expect to call as an expert witness at trial. With
respect to each person identified by you, please state:
(a)

The subject matter or area on which such expert is to testify;

(b)

The substance of the facts and opinions to which each such expert is
expected to testify; and

(c)

A summary of the grounds for each opinion of each expert.

Response:
In response to Interrogatory 1 Ms. Parsons submits the following: There will be no expert
witness.
2.
EMPLOYMENT SCHEDULE
Describe with particularity your employment schedule with respect to any and all of your
current employment.
Response:
In response to Interrogatory 2 Ms. Parsons submits the following: She has been employed at the
Georgia Institute of Technology since April 1, 2014. Her schedule during the summer term is

Monday through Friday from 8:00 AM 5:30 PM and 8:00 AM 5:00 PM the duration of the
year.
3.
EMPLOYMENT HISTORY/SOURCES OF INCOME
Describe with particularity all sources of income you currently have or have had in the
last three (3) years and for each source identified, please state the income amount.
Response: In response to Interrogatory 3 Ms. Parsons submits the following: Her sole source of
income has been from her employment at Georgia Institute of Technology.
4.
REAL PROPERTY
With respect to each parcel of tract of real estate (whether improved or unimproved) in
which you have any legal, equitable, marital, or beneficial interest, including leased or rented
property in which you have no ownership interest, please state the following:
(a)

The address by which such property is commonly known or referenced;

(b)

A full and complete description of your legal, equitable, marital or


beneficial interest in said property;

(c)

The date on which you acquired your interest in said property;

(d)

The purchase price of your interest in said property;

(e)

Your opinion as to the current fair market value for said property; and

(f)

A full and complete description of any and all documents which support
your responses to subparagraphs (a) and (e) above.
5.
AUTOMOBILES

For each automobile, truck, van, motorcycle, multi-purpose vehicle, all-terrain vehicle,
moped, motor scooter, motor vehicle, motor home, mobile home, trailer, boat, jet ski, airplane,
and tractor, in which you have any legal, equitable, marital, or beneficial interest, please state the
following:
(a)

A full and complete description of such item of property, including but not
limited to the year, make, model, and manufacturers identification or serial
number;

(b)

The date that you acquired an interest in said property;

(c)

The purchase price for your interest in said property;

(d)

Your opinion as to the fair market value of said property; and

(e)

A full and complete description of any and all documents which support
your responses to subparagraphs (a) through (d) above.

6.
RETIREMENT ACCOUNTS
For each retirement, pension, profit-sharing, stock ownership, stock option, and deferred
compensation plan and account in which you participate or in which you have any interest, legal,
beneficial or equitable (whether or not you interest is vested), please state the following:
(a)

The specific name of such plan;

(b)

The nature and type of such plan, i.e. a defined benefit plan, etc.;

(c)

Whether your interest is vested;

(d)

The current value of your interest in such plan; and

(e)

A full and complete description of each plan document referenced by you


in response to subparagraph (a) above.
7.
CASH ACCOUNTS

With respect to each banking, checking, savings, credit union, money market investment,
and any other similar account for which you are an authorized signatory, please state the
following:
(a)

The identity of the depositary bank, savings and loan association, credit union,
institution, and/or corporation for said account;

(b)

The account number for said account;

(c)

The identity of all persons in whose name the account was


established/opened;

(d)

The identity of all persons who are presently authorized signatories on said
account; and

(e)

The balance of the account as of January 1, 2010 and the date of your answers to
these Interrogatories.
8.
PERSONAL PROPERTY

With respect to each item of personal property (including but not limited to stocks, stock
options, bonds, mutual funds, commodities, futures, options, debentures, receivables, mineral
rights, precious metals, certificates of deposit, interests in proprietorships, partnerships,
syndicates, joint ventures and limited liability companies, artwork, antiques, collectibles, furs,
and jewelry) not otherwise described by you in response to Interrogatories 3 and 4 above having
a value equal to or exceeding $500.00, please state the following:
(a)

A full and complete description of such property, including serial numbers,


account numbers and/or certificate numbers;

(b)

The record owner of such property;

(c)

The date such property was acquired;

(d)

The purchase price for such property;

(e)

Your opinion as to the fair market value of such property; and

(f)

A full and complete description of any and all documents which support
your responses to subparagraphs (a) through (e) above.
9.
ONLINE ACCOUNTS

Please identify and give the name and online address for any and all online or electronic
accounts you maintain or regularly use for banking, bill payment, social networking or securities
trading.

10.
PERSONS WITH KNOWLEDGE
Please identify all persons whom you know or believe to have knowledge of the
following issues or areas of fact in this action:
(a)

The cause of separation;

(b)

Parental fitness of both parties;

(c)

The conduct of Plaintiff;

(d)

Your income, earnings, and earning capacity;

(e)

The assets and value of the assets accumulated during the marriage;

(f)

Your separate property and estate, if any and the value thereof.
11.
YOUR SEPARATE PROPERTY

Please describe with as much particularity as you can each property, which you contend
is your separate, non-marital asset.
12.
YOUR SPOUSES SEPARATE PROPERTY
Please describe each property you contend is your spouses separate, non-marital asset
with as much particularity as you can.
13.
SPOUSES MARITAL MISCONDUCT
Do you contend that from the date of your marriage to Plaintiff through and including the
date of your answer to this Interrogatory, your spouse has engaged in any act of marital
misconduct, as hereinabove defined? If so, please state:

(a)

A full and complete description of each alleged act of marital misconduct;

(b)

The exact or approximate date of such alleged act of marital misconduct;

(c)

The physical location (street number, city and state) of each such alleged act of
marital misconduct;

(d)

The identity of all persons who have knowledge or pertinent information


regarding your responses to subparagraphs (a) through (c) above; and

(e)

A description of each document, photographs, audio tape, audio visual tape, and
other graphic matter which you contend supports any of your responses to this
Interrogatory.
14.
YOUR MARITAL MISCONDUCT

From the date of your marriage to Plaintiff through and including the date of your answer
to this Interrogatory, have you engaged in any act of marital misconduct, as hereinabove defined?
If so, please state:
(a) A full and complete description of each alleged act of marital misconduct;
(b) The exact or approximate date of such alleged act of marital misconduct;
(c) The physical location (street number, city and state) of each such alleged act of
marital misconduct;
(d) The identity of all persons who have knowledge or pertinent information regarding
your responses to subparagraphs (a) through (c) above; and
(e)

A description of each document, photographs, audio tape, audio visual tape, and other
graphic matter which you contend supports any of your responses to this
Interrogatory.

15.
OWNERSHIP INTERESTS
Describe with particularity any partnership, corporation, or other business entity in which
you have a ten percent (10%) or greater interest in the last three (3) years. For each such entity,
please state the nature of your interest, the date you acquired the interest, the cost of your interest
and the current value of your interest.
16.
TRANSFERS OF PROPERTY
Have you transferred, sold, conveyed, pledged, loaned, hypothecated or given any
interest in any assets, cash or property, real or personal, tangible or intangible, of a value
exceeding $500.00, to any person, corporation, partnership, or other entity since the date of your
marriage to the time of trial? If so, identify and describe the transfer and the approximate
value(s), date(s), and recipient(s) of the transfer or transfers you have made.
17.
CAUSES OF THE SEPARATION
Please explain and give your supporting facts and your explanation of the cause(s) of
separation between your spouse and you in this marriage.
18.
RECORDINGS
State whether you have recorded or caused to be recorded any audio or video recordings
of the Plaintiff during the preceding twenty-four (24) months. If so, please identify the manner
in which such recordings were made, the number of such recordings, the date of such recordings,
and the identity of all individuals who were recorded along with Plaintiff.

This ______ day of _________________, 2016.


P. Justin Thrailkill
GABAR 940456
Attorney for Plaintiff
Miller & Brown, P.C.
P.O. Box 142908
Fayetteville, GA 30214
Tel. 770-461-2025
Fax 770-461-2026
jthrailkill@millerbrownlaw.com

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