July 4, 2021

Via E-Mail and U.S. Mail

Opposing Counsel’s Name, Esq.
Opposing Counsel’s Law Firm
Opposing Counsel’s Address 1
Opposing Counsel’s Address 2
Opposing Counsel’s City, State & Zip
Opposing Counsel’s E-Mail Address
Re: Petitioner’s Name v. Respondent’s Name
Correct County Superior Court
Civil Action File Number (Case Number)

Dear Opposing Counsel’s Name:

In reviewing Respondent’s responses to Petitioner’s First Continuing Interrogatories to

Respondent and the documents produced by Respondent in response to Petitioner’s First Notice
to Produce and Request for Production of Documents to Respondent, the following deficiencies
exist. Please note that the numbering aligns with our original discovery requests.

Petitioner’s First Notice to Produce and Request for Production of Documents to

Respondent

1. Respondent’s previously produced Preliminary Domestic Relations Financial

Affidavit does not accurately reflect current account balances and specifically states that
the figures are estimates. Respondent has received Respondent’s formal discovery
responses. Therefore, we request that Respondent provide an updated and more accurate
Domestic Relations Financial Affidavit
2. Respondent did not produce a proposed Parenting Plan. Please provide this
document as soon as possible.
3. Respondent did not produce a proposed Child Support Worksheet. Please provide
this document as soon as possible.
4. Respondent did not produce the following statements:
a. Citi Card (*_____): January 1, 2014 – January 14, 2015
July 18, 2015 – August 14, 2015
June 16, 2016 – September 15, 2016
January 16, 2017 - present

b. Please confirm that Respondent has no additional outstanding credit card

and/or charge account balances.
Opposing Counsel’s Name, Esq.
July 4, 2021
Page 2
__________________

5. Respondent did not produce the following statements:

a. Wells Fargo (*____): Account was identified in Respondent’s Interrogatory
responses; however, no statements were produced for this account.
b. SunTrust (*____): No statements were produced for this account.
6. Respondent did not produce statements for his Vanguard IRA account.
26. Respondent did not produce any evidence of his attempts to secure employment.
However, he acknowledges having made attempts. Please have him produce documents
evidencing those efforts.
27. Please provide Respondent’s proposed Child Support Worksheet along with proof
of any proposed deviations.
31. Please provide proof of any property in which Respondent contends he owns a
separate interest. Respondent is not in possession of any such documents as stated in his
response.
Petitioner’s First Continuing Interrogatories to Respondent

9. Please have Respondent supplement this response with all information requested,
including the dates of treatment and all details concerning such treatment.
10. Please have Respondent supplement this response with all information requested,
including any potential employers with whom he has submitted a resume or application
for employment, any career counselors he met with, websites he visited, posting he has
made, the positions he sought, and the date of such submission.
11. Respondent failed to identify Wells Fargo accounts ending *_____. Does
Respondent own any other deposit accounts?
12. Respondent failed to identify his Vanguard account. Does Respondent own any
retirement, stock, bond or security accounts?
18. Please have Respondent provide all terms and details concerning the 2009
inheritance from his great-aunt.
19. – 36. We disagree with your objection to these Interrogatories as exceeding the
allowable number of interrogatories including all sub-parts. Please have Respondent
respond immediately.
This letter is being sent pursuant to Uniform Superior Court Rule 6.4(B) as our good faith
effort to resolve this apparent discovery dispute. In the event supplemental responses are not
received within ten (10) days of the date of this letter, then Petitioner will have no choice but to
seek the Court’s assistance, including reimbursement of any and all associated attorney’s fees.
Opposing Counsel’s Name, Esq.
July 4, 2021
Page 3
__________________

Please do not hesitate to contact me with any questions or concerns.

Sincerely,

ELLARETHA COLEMAN
cc: Petitioner’s Name (via e-mail only)