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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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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.                                     )


DEFENDANT’S RESPONSES TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

COMES NOW Defendant Ron McKinney, in the above-styled action, and hereby files his responses and objections to Plaintiff Insulated Wall Systems, Inc.’s (herein after “Plaintiff”) Request for Production of Documents.
General Objections
Defendant objects to Plaintiff’s Request for Production of Documents generally to the extent that they seek to require Defendant to disclose information containing or reflecting privileged communications between Defendant and Defendant’s Wife, including the workproduct or mental impressions of his representatives.  Pursuant to the spousal privilege and work product immunity, the Defendant will not provide such protected information.
Defendant answers Plaintiff’s Requests by providing 209 additional pages of documentary evidence to supplement the documents already provided with Defendant’s Counterclaim which together are responsive to Plaintiff’s requests No.1 thru No.13, and further by providing written responses to each request as follows:

Production Request No. 1 Any and all written contracts, notes, and correspondence between you and Plaintiff.

Response to Production Request No. 1:
Defendant will continue to make available and has already made available documents in his possession, custody or control that are responsive to this request and they are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under requests No.6, No.7, No.8, No.10, No.11 and No.13.

Production Request No. 2 Any and all photographs, drawings, transparency, diagram, plat, or other graphic representations of the scene of the events complained of in this action or the alleged damaged residence.

Response to Production Request No. 2:
Defendant objects to this request on the grounds that it is vague, overly broad and seeks irrelevant information not calculated to lead to the discovery of evidence admissible in this case. Notwithstanding these objections, Defendant will continue to make available and has already made available documents in his possession, custody or control that are otherwise responsive to this request and more are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under requests No.5, No. 8 and No. 9. The investigation and discovery continues, and Defendant will supplement this response as additional information becomes available.

Production Request No. 3 Any and all invoices, bills, receipts and other documentary evidence in your possession related to the alleged damages that are the subject matter of Plaintiff’s Complaint or Defendant’s Counterclaim.

Response to Production Request No. 3: Defendant objects to this request on the grounds that it is vague, overly broad and seeks irrelevant information not calculated to lead to the discovery of evidence admissible in this case. Notwithstanding these objections, Defendant will continue to make available and has already made available documents in his possession, custody or control that are otherwise responsive to this request and more are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under requests No.1, thru No. 2, and No. 4 thru No. 13. The investigation, the Defendant’s medical treatment for injury resulting from Plaintiff’s negligence and discovery are continuing and Defendant will supplement this response as additional information becomes available.

Production Request No. 4 All documents of repair expenses and/or estimates received or incurred by you in connection with the Original Construction.

Response to Production Request No. 4:
Defendant will continue to make available and has already made available documents in his possession, custody or control that are otherwise responsive to this request and more are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under request No.3. The investigation and discovery are continuing and Defendant will supplement this response as additional information becomes available.

Production Request No. 5 Any and all photographs, drawings, diagrams, illustrations of any place or thing related to the incident which gives rise to the present lawsuit, including but not limited to any photographs of the residence taken before and after the original construction of same, any and all photographs, drawings, etc. of the in various stages of repairs, if any, and at the present, and any and all photographs of the damage alleged by you in your Counterclaim.

Response to Production Request No. 5:
Defendant objects to this request on the grounds that it is vague, overly broad and seeks irrelevant information not calculated to lead to the discovery of evidence admissible in this case. Notwithstanding these objections, Defendant will continue to make available and has already made available documents in his possession, custody or control that are otherwise responsive to this request and more are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under request No.2, No. 8 and No. 9.  The investigation and discovery continues and Defendant will supplement this response as additional information becomes available.

Production Request No. 6 Any written or recorded statements of any witness or party in connection with the events giving rise to the present suit.

Response to Production Request No. 6:
Defendant objects to this request on the grounds that it is vague, overly broad and seeks irrelevant information not calculated to lead to the discovery of evidence admissible in this case. Notwithstanding these objections, Defendant will continue to make available and has already made available documents in his possession, custody or control that are otherwise responsive to this request and more are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under requests No.1, No. 7, and No. 9 thru No. 13. The investigation and discovery continues and Defendant will supplement this response as additional information becomes available.

Production Request No. 7 Any and all correspondence between the parties in connection with the events giving rise to the present lawsuit.

Response to Production Request No. 7:
Defendant will make available and has already made available documents in his possession, custody or control that are responsive to this request and more are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under requests No.1, No. 6, No. 10, No. 11 and No. 13.  Discovery continues and Defendant will supplement this response as additional information becomes available.

Production Request No. 8 Any books, documents, or other tangible things, events, and any fact or circumstance upon which you rely to demonstrate or support relevant facts pertaining to the allegations complained in Defendant’s Counterclaim.

Response to Production Request No. 8:
Defendant objects to this request on the grounds that it is vague, overly broad and seeks irrelevant information not calculated to lead to the discovery of evidence admissible in this case. Notwithstanding these objections, Defendant will continue to make available and has already made available documents in his possession, custody or control that are otherwise responsive to this request and more are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under requests No.1, thru No. 7, and No. 9 thru No. 13. The investigation, the Defendant’s medical treatment for injury resulting from Plaintiff’s negligence and discovery are continuing and Defendant will supplement this response as additional information becomes available.

Production Request No. 9 Any and all documents and tangible things including but not limited to reports, memoranda, paper, notes, studies, photographs, videotapes, graphs, charts, tabulations,analyses, summaries, data sheets, statistical or information accumulations,data processing cards or worksheets and computer generated documents, including drafts or preliminary revisions of any of the above, prepared in connection with this litigation by or under the direction or supervision of any witness whom you expect to call as an expert witness at the trial of this matter.

Response to Production Request No. 9:
Defendant object to this request on the grounds that it is vague, overly broad and seeks irrelevant information not calculated to lead to the discovery of evidence admissible in this case. This request is not reasonably tailored to this particular case nor the issues relevant therein. Notwithstanding these objections, Defendant will supplement this response when an expert becomes necessary. Further, this request asks for a duplication of documents requested under requests No.6, and No. 12.

Production Request No. 10 A copy of any and all correspondence between you and/or your attorney and any party, witness or governmental body or official concerning the events that led to the complaint and Counterclaim.

Response to Production Request No. 10:
Defendant objects to this request on the grounds that it is vague, overly broad and seeks irrelevant information not calculated to lead to the discovery of evidence admissible in this case. Notwithstanding these objections, Defendant will continue to make available and has already made available documents in his possession, custody or control that are otherwise responsive to this request and more are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under requests No. 1, No. 6, No. 7 and No. 13. The investigation and discovery continues and Defendant will supplement this response as additional information becomes available.

Production Request No. 11 A copy of any and all contracts, agreements and proposals between the Plaintiff and Defendant.

Response to Production Request No. 11:
Defendant will continue to make available and has already made available documents in his possession, custody or control that are responsive to this request and more are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under requests No.1, and No. 7.

Production Request No. 12 A copy of any and all reports from any expert you have retained to use in the case, or to testify as an expert upon the trial of the case.

Response to Production Request No. 12:
Defendant will make available documents in his possession, custody or control that are responsive to this request when an expert becomes necessary. Further, this request asks for a duplication of documents requested under requests No. 6, and No. 9. Discovery and investigation continues and Defendant will supplement this response as additional information becomes available.

Production Request No. 13 A copy of any written letters, faxes or other correspondence relating to the alleged unsatisfactory work on the subject structure during the construction stage or at any time thereafter.

Response to Production Request No. 13:
Defendant will continue to make available and has already made available documents in his possession, custody or control that are responsive to this request and more are attached as Exhibits to Defendant’s Counterclaim. Further, this request asks for a duplication of documents requested under requests No.1, No. 6, No. 7, and No. 10. Discovery and investigation continues and Defendant will supplement this response as additional information becomes available.

This ______ day of September 2005.

DEFENDANT’S SUPPLEMENTAL RESPONSE TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS


COMES NOW Defendant Ron McKinney, in the above-styled action, and hereby files his supplemental response to Plaintiff Insulated Wall Systems, Inc.’s (hereinafter“Plaintiff”) Request for Production of Documents. The following specific request is hereby supplemented.
Production Request No. 2 Any and all photographs, drawings, transparency, diagram, plat, or other graphic representations of the scene of the events complained of in this action or the alleged damaged residence.

Response to Production Request No. 2:
Subject to and without waiving any previously made objections, Defendant hereby attaches color photographs taken by someone acting on Defendant’s behalf that are responsive to this request. These photographs include the original photographs taken and additional photographs taken subsequent to the ones supplied at the time of the Defendant’s initial response to this request. There will be more taken as the work continues to be redone.
This ______ day of August 2006.


Attached are 50 pages of color photographs,
containing mostly 6 photographs per page for a total of 298 photographs



















DEFENDANT’S RESPONSES TO PLAINTIFF’S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS




COMES NOW Defendant Ron McKinney, in the above-styled action, and hereby files his responses and objections to Plaintiff Insulated Wall Systems, Inc.’s (herein after “Plaintiff”) Request for Production of Documents.
General Objections
Defendant objects to Plaintiff’s Request for Production of Documents generally to the extent that they seek to require Defendant to disclose information containing or reflecting privileged communications between Defendant and Defendant’s Wife, including the workproduct or mental impressions of his representatives.  Pursuant to the spousal privilege and work product immunity, the Defendant will not provide such protected information.
Defendant answers Plaintiff’s Requests by providing____ additional pages of documentary evidence to supplement the documents already provided with Defendant’s Counterclaim and Defendant’s Response to Plaintiff’s First Request for documents and Supplementations already made which together are responsive to Plaintiff’s requests No.1 thru No.13, and 2nd No. 1 and 2nd No. 2 and further by providing written responses to each request as follows:

2nd Production Request No. 1 Any and all photographs, drawing, transparency, diagram, plat, or other graphic representation of the scene of the Replacement Construction.

Response to 2nd Production Request No. 1:
Relying on Plaintiff’s promise to pay, on August 31, 2006, Defendant provided printed copies of reconstruction photographs along with 100’s of other photographs previously requested and supplied to Plaintifff or a total of more than 298 photographs. Defendant will continue to make available and has already made available documents in his possession, custody or control that are responsive to this request.  

2nd Production Request No. 2 Any and all invoices, bills, receipts and other documentary evidence in your possession related to the Replacement Construction.

Response to 2nd Production Request No. 2:
Defendant objects to this request on the grounds that it is vague, overly broad and seeks irrelevant information not calculated to lead to the discovery of evidence admissible in this case. Notwithstanding these objections, Defendant will continue to make available and has already made available documents in his possession, custody or control that are otherwise responsive to this request. Further, this request asks for a duplication of documents requested under requests No.5, No. 8 and No. 9. The investigation, discovery and reconstruction is continuing, and Defendant will supplement this response as additional information becomes available.

This ______ day of September 2006.                            



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