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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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AFFIDAVITS FROM RON MCKINNEY INTRODUCING COUNTERCLAIM EXHIBITS A THRU K

filed July 20, 2005 BY Defendant.

AFFIDAVIT EXHIBIT A  

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says:
1.           My name is Ron McKinney.
2.           The two (2) page document attached and marked Defendants Exhibit "A is a true and correct copy of both sides of the Postcard I personally received sometime in July, 2004.
3.           I personally check the mail each day at the mailbox in front of the house.
4.           The Postcard is addressed to "Homeowner, 4083 Red Laurel Way, Snellville, GA 30039-6966."
5.           The return address is listed as John Tabor, 4169 Clairmont Rd, Chamblee, GA 30341 which is the same address as Insulated Wall Systems, the Plaintiff in this action.
6.           I have the original post card in my records.
7.           This is a copy of the original Postcard from my files and has not been altered or changed in any way from its original state except I added a phone number "770-986-8600" which is the phone number that I was told to use to call Mr. Tabor personally and I also added the words "Thursday 6:30" underlined to indicate the day and time of my first contact with Mr. Tabor, Plaintiff's representative, so everything else is exactly as it was received.
8.           The relevancy of this document is as follows:                       a.  It was Plaintiff who initiated the contact with Defendant.                       b.  It shows Plaintiff is asking for help.                       c.  It shows Plaintiff is advertising "Best Discounts on Name Brand Products"                       d.  It shows Plaintiff is advertising "Quality Work"                       e.  It shows Plaintiff is advertising "Satisfaction Guaranteed"

Ron McKinney, Defendant Pro Se
EACH OF THESE WERE SIGNED AND NOTARIZED WITH THE DOCUMENTS THEY SPEAK OF ATTACHED.

AFFIDAVIT EXHIBIT B

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says: 1.           My name is Ron McKinney. 2.           The one (1) page document attached and marked Defendants Exhibit "B" is a true and correct copy of one side of a business card handed to me personally by Plaintiff's representative John Tabor. 3.           I have the original business card in my records. 4.           The handwritten information is relevant to pricing and damagesf or the issues raised and has two sources, John Tabor, Plaintiff's representative and Defendant's spouse to be demonstrated at trial. 5.           The printed information on the card is exactly as it appears on the original and has not been altered in any manner by Defendant. 6.           The other main relevancy of this document lies in the motto printed at the bottom, "Let us make your home the home of your dreams..."

Ron McKinney, Defendant Pro Se
4083 Red Laurel Way Snellville, GA  30039 770-979-1254


AFFIDAVIT EXHIBIT C

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says: 1.       My name is Ron McKinney. 2.       The three (3) page document attached and marked Defendant's Exhibit "C is a true and correct copy of a letter I mailed to Plaintiff on December 20, 2004. 3.       The fourth page is a true and correct copy of the certified mail receipt and postal receipt. 4.       The return card was purchased but never received. 5.       This letter represents Defendant's first attempt to communicate in writing with Plaintiff's representative John Tabor concerning the issues involved in Defendant's Counterclaim.  

Ron McKinney, Defendant Pro Se 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

AFFIDAVIT EXHIBIT D

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says: 1.       My name is Ron McKinney. 2.       The one (1) page document attached and marked Defendant's Exhibit "D is a true and correct copy of a letter I mailed to Plaintiff on January 3, 2005. 3.       The second page is a true and correct copy of the certified mail receipt, postal receipt and the domestic return receipt. 4.       This letter represents Defendant's second attempt to communicate in writing with Plaintiff's representative John Tabor concerning the issues involved in Defendant's Counterclaim.

Ron McKinney, Defendant Pro Se 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

AFFIDAVIT EXHIBIT E

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says: 1.       My name is Ron McKinney. 2.       The three (3) page document attached and marked Defendant's Exhibit "E is a true and correct copy of a letter I mailed to Plaintiff on January14, 2005. 3.       The fourth page is a true and correct copy of the certified mail receipt, postal receipt, and domestic return receipt. 4.       This letter represents Defendant's third attempt to communicate in writing with Plaintiff's representative John Tabor concerning the issues involved in Defendant's Counterclaim. 5.       This letter is a response to Plaintiff's representative John Tabor's letter of January 4th, 2005. 6.       This letter also represents Defendant's first settlement offer, which has become invalid due to Plaintiff's rejection and upon new discoveries made by Defendant.

Ron McKinney, Defendant Pro Se 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

AFFIDAVIT EXHIBIT F

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says: 1.         My name is Ron McKinney. 2.         The three (3) page document attached and marked Defendant's Exhibit "F is a true and correct copy of a letter I received from Plaintiff's representative John J. Tabor on or about January 6, 2005 and has not been altered or changed in any way from its original state in which it was received. 3.         The fourth page is a true and correct copy of the envelope. 4.         The Domestic Return Receipt (green card) was signed by my wife or me. 5.         The relevancy of Plaintiff's representative's letter is the complete absence of "Satisfaction Guaranteed."

Ron McKinney, Defendant Pro Se 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

AFFIDAVIT EXHIBIT G

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says: 1.           My name is Ron McKinney. 2.           The three (3) page document attached and marked Defendant's Exhibit "G is a true and correct copy of a document entitled "Deck Additions to a Home - Building Permit Requirements" I personally received from the receptionist at the Gwinnett County Department of Planning and Development upon my inquiry as to information on the building of decks and has not been altered or changed in any way from its original state in which I received it. 3.           The relevancy of this document is that it demonstrates with pictures and descriptions some, but not all, Gwinnett County Code requirements regarding decks.  

Ron McKinney, Defendant Pro Se 4083 Red Laurel Way Snellville, GA  30039 770-979-1254
 

AFFIDAVIT EXHIBIT H

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says: 1.           My name is Ron McKinney. 2.           The three (3) page document attached and marked Defendant's Exhibit "H is a true and correct copy of a document entitled "Building Addition to a Home - Building Permit Requirement" I personally received from the receptionist at the Gwinnett County Department of Planning and Development upon my inquiry as to information on the building of concrete slabs and has not been altered or changed in any way from its original state in which I received it. 3.           The relevancy of this document is that it demonstrates with pictures and descriptions some, but not all, Gwinnett County Code requirements regarding concrete slabs.

Ron McKinney, Defendant Pro Se 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

AFFIDAVIT EXHIBIT I

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says: 1.           My name is Ron McKinney. 2.           The three (3) page document attached and marked Defendant's Exhibit "I is a true and correct copy of a Ted Lansing Order label for a particular window and two (2) National Fenestration Rating Council labels from two (2) windows installed at Defendant's residence and have not been altered or changed in any way from their original state. 3.           I personally witnessed my wife remove these labels as the windows arrived. 4.           The relevancy of these labels is the absence of the phrase "argon gas."

Ron McKinney, Defendant Pro Se 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

AFFIDAVIT EXHIBIT J

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says: 1.           My name is Ron McKinney. 2.           The two (2) page document attached and marked Defendant's Exhibit "J is a true and correct copy of a Ted Lansing Delivery Slip I received when the siding was delivered and it has not been altered or changed in any way from its original state in which I received it. 3.           The relevancy of this document is the absence of tape.

Ron McKinney, Defendant Pro Se 4083 Red Laurel Way Snellville, GA  30039 770-979-1254


AFFIDAVIT EXHIBIT K

BEFORE ME, personally appeared Ron McKinney, who being by me first duly sworn and identified in accordance with Georgia Law, deposes and says: 1.           My name is Ron McKinney. 2.           The two (2) page document attached and marked Defendant's Exhibit "K is a true and correct copy of a Home Depot Delivery Slip I received when the wood was delivered and has not been altered or changed in any way from its original state in which I received it. 3.           The relevancy of this document is the absence of anything remotely resembling plywood or siding boards.

Ron McKinney, Defendant Pro Se 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

State of Georgia, County of Gwinnett BEFORE ME personally appeared, Ron McKinney who, being by me first duly sworn and identified in accordance with Georgia law, did execute the foregoing in my presence This ____ day of ____________ 2005, __________________________ Notary Public     My commission expires:


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