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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.
IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA
INSULATED WALL SYSTEMS, INC., )
Plaintiff, )
) Civil Action File No.:
v. ) 05A06942-9
)
RON MCKINNEY, )
Defendant. )
NOTICE TO TAKE DEPOSITION OF PLAINTIFF
To: INSULATED WALLSYSTEMS, INC.
4169 Clairmont Road, Chamblee, Georgia 30341
c/o Jana B. Tabor, Attorney for Plaintiff
450 Arborshade Trace
Duluth, GA30097
(770)814-8134
PLEASE TAKE NOTICE that on February 6, 2007 beginning at 10:00 a.m. at the Centerville Community Center,3025 Bethany Church Road, Snellville Georgia 30039, the Defendant in the above-styled action, pursuant to O.C.G.A 9-11-30(b)(6) will proceed to take the deposition upon oral examination of Plaintiff, INSULATED WALL SYSTEMS, INC for purposes of discovery and cross examination and any other purpose permitted by the Georgia Civil Practice Act and the Georgia Rules of Evidence.
The matters upon which Plaintiff will be deposed include the following as they relate to Defendant (1) Sales (2) Marketing (3) Contracts or agreements (4) industry standards for construction and installation (5) subcontractors (6) Worker/subcontractor qualifications and experience (7) products (8) warranties (9) guarantees (10) product suppliers (11) remedial work (12) collections (13) litigation history (14) corporate history and experience (15) corporate services (16) corporate policy (17) Quality assurance standards (18) dispute resolution (19) Plaintiff's Complaint and (20) Defendant's Answer and Counterclaims.
The deposition will be taken before a Certified Court Reporter authorized to administer oaths and to take depositions by stenographic means. The oral examination will continue from day to day, until its completion. A copymachine will be available.
Respectfully submitted this _______ day of January 2007.
_____________________________
Ron McKinney, Defendant
4083 Red Laurel Way
Snellville, GA 30039
770-972-2576
Jana B. Tabor, Attorney for Plaintiff
450 Arborshade Trace,
Duluth, GA 30097
(770) 814-8134
IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA
INSULATED WALL SYSTEMS, INC., )
Plaintiff, )
) Civil Action File No.:
v. ) 05A06942-9
)
RON MCKINNEY, )
Defendant. )
CERTIFICATE OF SERVICE
UNDER PENALTY OF PERJURY, I CERTIFY that a true and exact copy of Defendant’s:
NOTICETO TAKE DEPOSITION OF PLAINTIFF
was provided to Plaintiffs Attorney at the address listed below by depositing the same in the United States Mails, CERTIFIED RETURN RECEIPT REQUESTED and regular mail with sufficient postage thereon
this ______ day of January 2007.
_____________________________
Ron McKinney, Defendant
4083 Red Laurel Way
Snellville, GA 30039
770-972-2576
Jana B. Tabor, Attorney for Plaintiff
450 Arborshade Trace
Duluth, GA 30097
(770) 814-8134
IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA
INSULATED WALL SYSTEMS, INC., )
Plaintiff, )
) Civil Action File No.:
v. ) 05A06942-9
)
RON MCKINNEY, )
Defendant. )
NOTICE TO PRODUCE ORIGINAL DOCUMENTS
To: INSULATED WALLSYSTEMS, INC.
4169 Clairmont Road, Chamblee, Georgia 30341
c/o Jana B. Tabor, Attorney for Plaintiff
450 Arborshade Trace
Duluth, GA30097
(770)814-8134
PLEASE TAKE NOTICE, Pursuant to O.C.G.A. 24-10-26 Plaintiff is hereby notified to bring with it to a deposition the originals ofany and all documents previously produced and previously requested that have not been produced under the Requests For Production of Documents done pursuant to O.C.G.A 9-11-34(a). Pursuant to O.C.G.A. 24-10-26 Plaintiff is noticed to produce the documents, records, reports, photographs, videos and tangible things at the time of any hearing, deposition and trial of the above styled case.
Respectfully submitted this _______day of January 2007.
_____________________________
Ron McKinney, Defendant
4083 Red Laurel Way
Snellville, GA 30039
770-972-2576
Jana B. Tabor, Attorney for Plaintiff
450 Arborshade Trace, Duluth, GA30097 (770) 814-8134
IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA
INSULATED WALL SYSTEMS, INC., )
Plaintiff, )
) Civil Action File No.:
v. ) 05A06942-9
)
RON MCKINNEY, )
Defendant. )
CERTIFICATE OF SERVICE
UNDER PENALTY OF PERJURY, I CERTIFY that a true and exact copy of Defendant’s:
NOTICE TO PRODUCE ORIGINAL DOCUMENTS
was provided to Plaintiffs Attorney at the address listed below by depositing the same in the United States Mails, CERTIFIED RETURN RECEIPT REQUESTED and regular mail with sufficient postage thereon
this ______ day of January 2007.
_____________________________
Ron McKinney, Defendant
4083 Red Laurel Way
Snellville, GA 30039
770-972-2576
Jana B. Tabor, Attorney for Plaintiff
450 Arborshade Trace
Duluth, GA 30097
(770) 814-8134
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