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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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CURRENT CASE DOCKET -  CONTRACT LAWSUIT                    Next Document       Previous Document
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 OF FILING
  
Pursuant to Section 29.1 of the Georgia Civil Practice Act (O.C.G.A. 9-11-29.1), Defendant Ron McKinney hereby requests the Court and Plaintiff to take notice of the original discovery items shown listed below which were filed with the Court and docketed on the following dates:
  
1.  DOCKETED 07/20/2005 - DEFENDANT'S VERIFIED ANSWER AND AFFIRMATIVE DEFENSES

2.  DOCKETED 07/20/2005 - DEFENDANT'S VERIFIED COUNTERCLAIM

3.  DOCKETED 07/20/2005 - DEFENDANT'S JURY DEMAND
 
4.  DOCKETED 06/09/2006 - 1ST AMENDMENT TO DEFENDANT'S VERIFIED ANSWER AND AFFIRMATIVE DEFENSES

5. DOCKETED 09/19/2005 - DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
(Plaintiff's Requests # 1-13 and with it Plaintiff was provided 209 pages of evidence documents)

6. DOCKETED 09/19/2005 - DEFENDANT'S RESPONSES TO PLAINTIFF INSULATED WALL SYSTEMS, INC'S FIRST INTERROGATORIES TO DEFENDANT
(Plaintiff's Questions # 1-11)

7. DOCKETED 08/03/2006 - DEFENDANT'S FIRST AMENDMENT TO PLAINTIFF'S FIRST INTERROGATORIES TO DEFENDANT
(Supplement to Plaintiff's Questions # 1, 9, 10, 11 and Verification)

8. DOCKETED 09/01/2006 - DEFENDANT'S SUPPLEMENTAL RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
(Supplement to Plaintiff's Request # 2, and with it Plaintiff was provided 298 evidence photographs on 50 pages)

9. DOCKETED 09/26/2006 - DEFENDANT'S RESPONSE TO PLAINTIFF INSULATED WALL SYSTEMS, INC'S SECOND INTERROGATORIES TO DEFENDANT
(Plaintiff's Questions # 1-4)

10. DOCKETED 09/26/2006 - DEFENDANT'S RESPONSE TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS
(Plaintiff's Request # 1-2 and with it Plaintiff was provided 63 additional pages of evidence documents)

11. DOCKETED 06/14/2007 - DEFENDANT'S SUPPLEMENTAL RESPONSES TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS
(Supplement to Plaintiff's Request # 1, 2 and with it Plaintiff was provided 60 evidence photographs on 10 pages and 141 pages of evidence documents consisting of Exhibits #1-32 from the John Tabor Deposition)

12. DOCKETED 05/03/2007 - DEPOSITION ROBYN MCKINNEY (with errata sheets)

13. DOCKETED 05/03/2007 - DEPOSITION RON MCKINNEY (with errata sheets)

Defendant requests that these original items of discovery filed with the court previously, be made available now for use and consideration with the pending Defendant's Opposition to Plaintiff's Motion for Partial Summary Judgment.
  
This ___ day of July, 2007.
  
  
________________
Ron McKinney
  
NOTICE OF FILING
  
Pursuant to Section 29.1 of the Georgia Civil Practice Act (O.C.G.A. 9-11-29.1), Defendant Ron Mckinney hereby requests the Court and Plaintiff to take notice of the original discovery items shown listed below which were filed with the Court and docketed on the following dates:
  
1.  DOCKETED 07/05/2005 - AFFIDAVIT RON MCKINNEY
(Motion to Dismiss)

2.  DOCKETED 07/05/2005 - AFFIDAVIT RON MCKINNEY
(Motion to Strike)

3.  DOCKETED 07/20/2005 - AFFIDAVIT RON MCKINNEY
(11 individual Affidavits, one for each of the 11 Exhibits attached to the Verified Answer and Counterclaim)

4. DOCKETED 11/14/2005 - AFFIDAVIT RON MCKINNEY
(Motion for PO)

5. DOCKETED 01/06/2006 - AFFIDAVIT ROBYN MCKINNEY
(Introduces Macon Gooch Building Consultants Inspection Report)

6. DOCKETED 04/13/2006 - AFFIDAVIT  LYNN WHYTE
(proof the Windows did not contain argon gas)

7. DOCKETED 04/13/2006 - ATRIUM LETTER
(includes Window Brochures and Window Order Statement)  

8. DOCKETED 06/09/2006 - AFFIDAVIT RON MCKINNEY
(Induced into signing contract by false statements made by John Tabor, 1st Amendment to Def. Answer)

9. DOCKETED 06/14/2006 - AFFIDAVIT ROBYN MCKINNEY
(Introduced other Contract Documents, letters, liens, Complaints)

10.  DOCKETED 08/03/2006 - HOUSE SMART INSPECTIONS, Keith Cook Inspection Report
  
11.  DOCKETED 08/03/2006 - SEQUOYAH VINYL CREATIONS, INC,  
(Initial Replacement Cost Proposal, Thomas Vaughn)

12. DOCKETED 08/22/2006 - AFFIDAVIT RON MCKINNEY
(Motion for Sanctions and Response to Motion for PO)

13. DOCKETED 08/22/2006 - AFFIDAVIT ROBYN MCKINNEY
(Motion for Sanctions and Response to Motion for PO)

14. DOCKETED 09/06/2006 - AFFIDAVIT RON MCKINNEY
(Motion to Extend Discovery - Macon Gooch Licensing documents, discovery disputes )

15. DOCKETED 09/18/2006 - AFFIDAVIT RON MCKINNEY
(Response to Motion to Compel Photographs)

16. DOCKETED 09/18/2006 - AFFIDAVIT ROBYN MCKINNEY
(Response to Motion to Compel Photographs)

17. DOCKETED 09/26/2006 - AFFIDAVIT RON MCKINNEY
(Forgery Investigation)

18. DOCKETED 09/26/2006 - AFFIDAVIT FARRELL C SHIVER
(Forgery Investigation)

19. DOCKETED 02/16/2007 - AFFIDAVIT RON MCKINNEY
(Motion to Compel)

20. DOCKETED 05/04/2007 - AFFIDAVIT ROBYN MCKINNEY
(Motion to Compel)

21. DOCKETED 05/14/2007 - AFFIDAVIT ROBYN MCKINNEY (AMENDED 5-12-07)

22. DOCKETED 06/04/2007 - AFFIDAVIT RON MCKINNEY
(Response to Motion PSJ)

23. DOCKETED 06/04/2007 - AFFIDAVIT ROBYN MCKINNEY
(Response to Motion PSJ)

Defendant requests that these original items of discovery filed with the court previously, be made available now for use and consideration with the pending Defendant's Opposition to Plaintiff's Motion for Partial Summary Judgment.
  
This ___ day of July, 2007.
 
________________
Ron McKinney
  
  
NOTICE OF FILING
  
Pursuant to Section 29.1 of the Georgia Civil Practice Act (O.C.G.A. 9-11-29.1), Defendant Ron McKinney hereby requests the Court and Plaintiff to take notice of the original discovery items shown listed below which were filed with the Court and docketed on the following dates:
  
1.  DOCKETED 08/31/2005 - DEFENDANT'S FIRST CONTINUING REQUEST FOR ADMISSIONS TO PLAINTIFF (Requests # 1-16 including subparts 1-43 and 17-20)  
  
2.  DOCKETED 06/02/2006 - NOTICE OF FILING DISCOVERY Filed By: DEFENDANT
Plaintiff’s Responses to Defendant’s First Continuing Request For Admissions – dated September 29, 2005.
Amendment to Plaintiff’s Responses to Defendant’s First Continuing Request For Admissions– dated October 27, 2005.

3.  DOCKETED 08/31/2005 - DEFENDANT'S FIRST CONTINUING INTERROGATORIES TO INSULATED WALL SYSTEMS, INC. (Questions # 1-13)
  
4.  DOCKETED 06/02/2006 - NOTICE OF FILING DISCOVERY Filed By: DEFENDANT
Plaintiff Insulated Wall Systems, Inc. Responses to Defendant’s First Continuing Interrogatories – dated September 29, 2005.
Amendment to Plaintiff’s Response to Defendant’s First Continuing Interrogatories – dated October 27, 2005.

5.  DOCKETED 08/03/2006 - NOTICE OF FILING DISCOVERY Filed By: DEFENDANT
Plaintiff’s Second Amendment to Defendant’s First Continuing Request For Interrogatories– dated July 13, 2006.
Third Amendment to Plaintiff Responses to Defendant’s First Continuing Interrogatories – dated July 30, 2006.

6.  DOCKETED 08/31/2006 - NOTICE OF FILING DISCOVERY Filed By: DEFENDANT  
CHAMPIA Real Estate Inspection Report – dated July 5, 2006.

7.  DOCKETED 08/31/2005 - DEFENDANT'S FIRST CONTINUING REQUEST FOR PRODUCTION OF DOCUMENTS TO INSULATED WALL SYSTEMS, INC. (Requests # 1-13)
  
8.  DOCKETED 06/02/2006 - NOTICE OF FILING DISCOVERY Filed By: DEFENDANT
Plaintiff’s Responses to Defendant’s First [Continuing] Request for Production of Documents– dated September 29, 2005.

9.  DOCKETED 11/29/2005 - DEFENDANT'S SECOND CONTINUING REQUEST FOR PRODUCTION OF DOCUMENTS AND INTERROGATORIES TO PLAINTIFF (Requests # 14-16 and Questions #14-28)
  
10.  DOCKETED 06/02/2006 - NOTICE OF FILING DISCOVERY Filed By: DEFENDANT
Plaintiff’s Response to Defendant’s Second Continuing Request for Production of Documents and Interrogatories to Plaintiff – dated December 21, 2005.

11.  DOCKETED 01/03/2006 - DEFENDANT'S THIRD CONTINUING REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF (Requests # 17-22)
  
12.  DOCKETED 06/02/2006 - NOTICE OF FILING DISCOVERY Filed By: DEFENDANT
Plaintiff’s Response to Defendant’s Third Continuing Request for Production of Documents –dated January 25, 2006.

13.  DOCKETED 12/05/2005 - DEFENDANT'S SECOND CONTINUING REQUEST FOR ADMISSIONS TO PLAINTIFF (Requests # 1-300)

14.  DOCKETED 08/03/2006 - NOTICE OF FILING DISCOVERY Filed By: DEFENDANT
Plaintiff’s Responses to Defendant’s Second Continuing Request For Admissions – dated July 17, 2006.

15.  DOCKETED 01/18/2007 - DEFENDANT'S NOTICE TO PRODUCE
(Produce originals of all documents Defendant has requested at Hearings and Trial)

16. DOCKETED 02/16/2007 - DEFENDANT'S THIRD CONTINUING REQUEST FOR ADMISSIONS TO PLAINTIFF (Requests # 1-20)

17.  DOCKETED 07/06/2007 - RESPONSE TO DEF REQ FOR ADMISSIONS Filed By: ATTORNEY FOR PLAINTIFF

18.  DOCKETED 04/07/2007 - DEPOSITION JOHN TABOR 02-06-2007
(Transcript as submitted for review to John Tabor, no errata sheet was returned)

19.  DOCKETED 05/04/2007 - NOTICE OF FILING DISCOVERY Filed By: DEFENDANT
2 Letters from Rajani Reporting, Inc., Certified Court Reporter - dated  March 16, 2007 and April 4, 2007

Defendant requests that these original items of discovery filed with the court previously, be made available now for use and consideration with the pending Defendant's Opposition to Plaintiff's Motion for Partial Summary Judgment.

  
This ___ day of July, 2007.
 
________________
Ron McKinney

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