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To put this case all on the Record, all Discovery, both Requests and Responses were filed with the Clerk of the Court by the Defendant Pro Se, not just the Certificates of Service.
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Ron McKinney
4083 Red Laurel Way,
Snellville, GA 30039

Georgia Diagnostic and
Classification State Prison
Post Office Box 3877
Jackson, Georgia 30233                                               DELIVERY CONFIRMATION #
Highway 36, West, Butts County                                    0307 3330 0000 9192 1801
Phone: (770) 504-2000
Fax: (770) 504-2006                                                               March 10, 2008
                
Re: Requesting Time and Space To Take A Deposition of Life Inmate
HILTON, GARY MICHAEL GDC ID: 0000236663
 
Dear Warden Hilton Hall and Deputy Warden Security Henry Brooks,
  
     My name is Ron McKinney. I am the Plaintiff in a Counterclaim in a Civil Lawsuit in Gwinnett County Superior Court Case #  05-A-06942-9 involving Insulated Wall Systems and John J. Tabor, the former employer of Gary Michael Hilton, AKA Mack Hilton. Mr. Hilton is a named witness in that case whose testimony has not yet been secured. I need to obtain the sworn testimony from Mr. Hilton in the form of a Deposition for use in this case.
 
      Previous to these horrific events, I had been unable to secure the information regarding Mr. Hilton's true identity and his whereabouts from his employer or the attorney, in order to schedule that Deposition. Now that Mr. Hilton's identity and whereabouts are known, I hope to complete that deposition as soon as practically possible. I understand Hilton has been indicted in Florida on another murder charge. I do not wish to interfere in anyway with that murder case however his testimony is critical in my case, so the soonest it can be done the better.
  
     Please inform me of what arrangements will need to be made in order for Mr. Hilton's Deposition to take place in your prison facilities there in Jackson. You can contact me either by phone or mail at the above address. I will need to hear back from you just as soon as possible so that I can obtain any court orders if required from the Judge in this case. The Judge in this case is Honorable Tom Davis, Judge of the Gwinnett Superior Court. His office can be reached at 770-822-8585 and by Fax at 770-822-8584.
  
   I look forward to hearing from you.

Sincerely,


Ron McKinney, pro se
770-972-2576

CC to:
Honorable Judge Tom Davis
Gwinnett County Superior Court
Gwinnett County Justice and Admin. Center
75 Langley Drive
Lawrenceville, GA  30045
770-822-8585,  Fax: 770-822-8584.

Kevin T. Moore, PC, Attorney for Defendant in Counterclaim
6111 Peachtree Dunwoody Rd. NE
Building C, Suite 201
Atlanta, GA  30328-4522
770-396-3622
770-551-8701


IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA

INSULATED WALL SYSTEMS, INC.,             )
                                                                   )
Plaintiff,                                                       )
                                                                  )    Civil Action File No.:  
v.                                                                )         05A 06942-9
                                                                  )
RON MCKINNEY,                                        )
                                                                  )
           Defendant.                                        )

CERTIFICATE OF SERVICE

     UNDER PENALTY OF PERJURY, I CERTIFY that a true and exact copy of the attached Letter Correspondence Regarding Deposition of Gary Michael Hilton sent to The Georgia Diagnostic and Classification State Prison and copied to the Judge was provided to Plaintiffs Attorney at the address listed below by depositing the same in the United States Mails, with sufficient postage thereon

this __10th_ day of March  2008.
 _____________________________
Ron McKinney, pro se Defendant
and Plaintiff in Counterclaim
4083 Red Laurel Way
Snellville, GA  30039
770-972-2576

Kevin T. Moore, PC, Attorney for Plaintiff
and Defendant in Counterclaim
6111 Peachtree Dunwoody Rd. NE
Building C, Suite 201
Atlanta, GA  30328-4522
770-396-3622
770-551-8701

Current Track & Confirm e-mail information provided by the U.S. Postal Service.

Label Number: 0307 3330 0000 9192 1801
Service Type: DELIVERY CONFIRMATION

Shipment Activity        Location                               Date & Time
--------------------------------------------------------------------------------
Delivered                JACKSON GA 30233                       03/11/08  7:37am

Arrival at Unit          JACKSON GA 30233                       03/11/08  7:09am

Processed                ATLANTA GA 30320                       03/10/08  6:39pm

Acceptance               SNELLVILLE GA 30039                    03/10/08  2:57pm


Robyn McKinney
4083 Red Laurel Way,
Snellville, GA 30039


Georgia Diagnostic and
Classification State Prison
Post Office Box 3877
Jackson, Georgia 30233                                      DELIVERY CONFIRMATION #
Highway 36, West, Butts County                            0307 3330 0000 9193 3729      
Phone: (770) 504-2000
Fax: (770) 504-2006                                                                       April 21, 2008
                
Re: Requesting Urgent Mail Delivery to Life Inmate
HILTON, GARY MICHAEL GDC ID: 0000236663
 
Dear Warden Hall,
 
Enclosed please find URGENT MAIL for delivery to inmate Gary Michael Hilton. Previously a request was being made to take a deposition of this inmate for use in Gwinnett County Superior Court Case # 05-A-06942-9. However that case will be proceeding to trial very shortly and I understand Mr. Hilton may also be proceeding to Florida shortly. The case involves work Mr. Hilton performed for Insulated Wall Systems and John J. Tabor, his former employer. At this time if you will allow Mr. Hilton to receive this mail and respond in writing voluntarily to the enclosed requests, a deposition may not be necessary.
 
I have enclosed the written requests on a separate letter and blank paper for Mr. Hilton to use for writing his response. Included also is a verification statement for Mr. Hiltonís response to be notarized if it is possible to have this statement notarized. The verification statement itself should suffice for his statement to be used in court. I have enclosed a stamped self addressed envelope for Mr. Hiltonís response to be mailed back to me and some dollars to cover any additional expenses.
 
I thank you in advance for your time in seeing that this matter gets into the hands of Mr. Hilton so he can provide the much needed response as soon as possible.

Sincerely,


Robyn McKinney
770-972-2576
 
Robyn McKinney
4083 Red Laurel Way,
Snellville, GA 30039

Georgia Diagnostic and
Classification State Prison
Post Office Box 3877
Jackson, Georgia 30233                                      DELIVERY CONFIRMATION #
Highway 36, West, Butts County                           0307 3330 0000 9193 3729
Phone: (770) 504-2000
Fax: (770) 504-2006                                                                 April 21, 2008
                
Re: Urgent Mail Delivery to Life Inmate
HILTON, GARY MICHAEL GDC ID: 0000236663
 
To the Attention of Gary Michael Hilton, aka Mack Hilton
 
Mr. Hilton you are named as a witness in a civil lawsuit involving your former boss John Tabor and Insulated Wall Systems. Obviously at this point coming to the trial will not be permitted. In lieu of taking your deposition under the circumstances, a voluntary response in writing to this letter is requested regarding the matter in question. There are a million things I would really like to ask you but a response to these few questions will do for now.

Mr. Hilton, what if anything do you remember concerning a remodeling project done at our home in October-November 2004 that is the subject of this civil lawsuit filed in June 2005 involving John Tabor, Jana Tabor, Insulated Wall Systems or any of the workers who participated on this failed home improvement project?
 
    Our homes address is 4083 Red Laurel Way, Snellville, GA 30039. Living in the home at the time was Robyn McKinney, Ron McKinney and his 93 year old mother Lois McKinney, and a pure bred beagle dog named Molly. The work that was to be done was windows, siding, gutters, 2 decks and a foundation slab.

    If you do not remember anything, please provide a written response anyway so stating. If you do remember this project and are willing to provide a response, please write down as much information as you can remember to these requests.

1.)    State any events you recall leading up to the project in 2004?
2.)    State any events you recall occurring on the project in 2004?
3.)    State any events that you have personal knowledge of that you can recall happening during the years 2004, 2005, 2006, and 2007 which may relate in anyway to this project or to this litigation and state the names of the individuals involved?
4.)    State the amount of money you received in payment for your role on this project and for what tasks and from whom you received it?
   

    I have included a page containing photographs of the home prior to the project and after the failed project. I have included extra paper for you to write on and a postage paid envelope for you to mail your response back in. If you will, please sign your response, and if possible have it notarized. Please return all three pages of this letter with your response. I have included a few dollars to cover any additional costs involved with obtaining your response.

    Your response is requested in a timely manner as this litigation will be proceeding to a jury trial in the very near future.

Thank you for your time and full consideration of this request.

Robyn McKinney

SWORN VERIFICATION IN RESPONSE
AND AUTHENTICATION OF SIGNATURE
 
This verification covers my responses given to the above written questions as attached. I Gary Michael Hilton provide this sworn statement voluntarily. This statement and the pages attached are my response given to the best of my recollection of the events in question which occurred during the years 2004, 2005, 2006, and 2007. I am providing these responses for use and consideration in my absence, as I am an inmate in custody and unable to appear in court to give live testimony in case #05A 06942-9 in the Superior Court of Gwinnett County Georgia, in which I am named as a witness. I have personal knowledge of the matters stated here in my response and I am competent to make this statement.

This sworn response was provided on the ______day of ______________, 2008.
 

______________________
Signed by Gary Michael Hilton
 
STATE OF GEORGIA, County of ___________________
 
BEFORE ME personally appeared, Gary Michael Hilton who, being by me first duly sworn and identified in accordance with Georgia law, did execute the foregoing in my presence
 
This ____ day of ____________ 2008,
 
__________________________ Notary Public
 
My commission expires:


USPS TRACK AND CONFIRM

Current Track & Confirm e-mail information provided by the U.S. Postal Service.

Label Number: 0307 3330 0000 9193 3729
Service Type: DELIVERY CONFIRMATION
Shipment Activity      Location                       Date & Time
------------------------------------------------------------------
Delivered             JACKSON GA 30233             04/22/08  6:58am

Arrival at Unit      JACKSON GA 30233              04/22/08  6:45am

Processed           ATLANTA GA 30320                04/21/08  6:36pm

Acceptance         SNELLVILLE GA 30039            04/21/08  2:04pm
------------------------------------------------------------------

 

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