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JILL SHERIDAN http://www.jilliansheridan.comIN THE STATE COURT OF GWINNETT COUNlY STATE OF GEORGIAEXHIBIT DMIDLAND FUNDING LLC, ASSIGNEE OF CHASE BANK (USA), N.A.,Plaintiff,vs. JILL SHERIDAN CIVIL ACTION FILE NO. 10-7271-4Defendant.RESPONSE TO DEFENDANT'S REQUEST FOR ADMISSIONSCOMES NOW Plaintiff, by and through counsel, and responds to Defendant's Request for Admissions, as set forth in the following manner below: GENERAL OBJECTIONS Plaintiff generally objects and responds to the Requests on the grounds set forth in paragraph
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IN THE STATE COURT OF GWINNETT COUNlY STATE OF GEORGIA
MIDLAND FUNDING LLC, ASSIGNEE OF CHASE BANK (USA), N.A.,
Plaintiff,
vs. CIVIL ACTION FILE NO. 10-7271-4
JILL SHERIDAN
Defendant.
RESPONSE TO DEFENDANT'S REQUEST FOR ADMISSIONS
COMES NOW Plaintiff, by and through counsel, and responds to
Defendant's Request for Admissions, as set forth in the following manner below:
GENERAL OBJECTIONS
Plaintiff generally objects and responds to the Requests on the grounds set
forth in paragraphs "A" through "u" below. All general objections shall be
deemed to be continuing and shall be construed as supplementing each specific
objection and/or response to the Requests. No specific objection and no
response contained herein shall be interpreted as limiting in any way the scope or
effect of any general objection. Plaintiff objects generally to the Requests to the
extent they exceed the scope permitted by O.C.G.A. § 9-11-36.
A. Plaintiff objects generally to the Requests to the extent they
exceed the scope permitted by O.C.G.A. § 9-11-36.
B. Plaintiff objects generally to the Requests to the extent they
exceed the scope permitted by O.C.G.A. § 9-11-36 as there is no requirement that
responses to Requests for Admissions be verified.
C. Each response is subject to all objections as to relevance and
materiality or any other objections that would require the exclusion of any
statement herein if such statement were to be made by a witness present and
testifying in Court.
D. A response to any Request is not intended and should not be
construed to be a waiver by Plaintiff of all or any part of any objection to any
Request.
E. Plaintiff objects generally to the Requests to the extent they
assume facts that are inaccurate.
F. Plaintiff objects generally to the Requests to the extent they
are argumentative.
G. Plaintiff objects generally to the Requests to the extent they
are defective in form.
H. Plaintiff objects generally to the Requests to the extent they
are overly broad.
I. Plaintiff objects generally to the Requests to the extent they
are unduly burdensome.
J. Plaintiff objects generally to the Requests to the extent they
are oppreSSIve.
K. Plaintiff objects generally to the Requests to the extent they
are not reasonably calculated to lead to the discovery of admissible evidence.
L. Plaintiff objects generally to the Requests to the extent they
impose on it an unreasonable burden of inquiry.
M. Plaintiff objects generally to the Requests to the extent they
seek information that is subject to the attorney-client privilege, work product
privilege, or any other privilege or legal protection. The inadvertent or mistaken
production of information and/ or documents subject to the protections of the
attorney-client privilege, work product privilege, or any other privilege or legal
protection shall not constitute a general, inadvertent, implicit, subject matter,
separate, independent, or other waiver of such privilege or protection and does
not put in issue or constitute the affirmative use of the advice of counselor of any
privileged communications. All such inadvertently produced information and/or
documents shall be returned to Plaintiffs attorneys, along with any copies made
thereof.
N. Plaintiff objects generally to the Requests to the extent they
seek information that is of a confidential, proprietary, or trade secret nature.
O. Plaintiff objects generally to the Requests to the extent they
seek information that was prepared in anticipation oflitigation.
P. Plaintiff objects generally to the Requests to the extent they
are not properly limited as to time.
Q. Plaintiff objects generally to the Requests to the extent they
seek conclusions or request opinions or contentions that relate to the application
of law to facts.
R. Plaintiff reserves its right to supplement its objections and
responses to the Requests to the extent necessary and appropriate.
.--
S. Plaintiff objects to each Request as to which the information
known or readily obtainable by Plaintiff is insufficient to enable Plaintiff to admit
or deny the Request.
T. Plaintiff objects to each Request to the extent that it seeks
information that contains or reflects personal, proprietary or confidential
information, or other non-public business information.
U. Plaintiff objects to the Requests to the extent they do not
relate to the claims and defenses set forth in the pleadings.
of:
RESERVATIONS
1. These responses are made without waiver of, and with preservation
(a) The right to object to all Requests as to competency,
relevancy, materiality, confidentiality, privilege, and admissibility of the
responses, or the subject matter thereof, as evidence for any purpose in
any further proceeding in this action (including the trial of this action) or
in any other action;
(b) The right to object to the use of any such responses, or the
subject matter thereof, on any ground in any further proceeding in this
action (including the trial of this action) or in any other action;
(c) The right to object on any ground to any Request revised by
Defendant in response to any objection herein that a Request, or any part
thereof, is vague, ambiguous, overbroad, or unduly burdensome; and
(d) The right at any time to revise, correct, add to, supplement
or clarify any of the responses contained herein.
2. The following responses, and any further responses to the Requests,
or to their subject matter, are made expressly without acknowledgment of
materiality or relevance of the Requests, or that the Requests are in any way
reasonably calculated to lead to the discovery of admissible evidence.
SPECIFIC OBJECTIONS AND RESPONSES
1. Admitted. Plaintiff has provided all documents that are currently within
Plaintiffs possession, and will supplement discovery when appropriate.
2. Denied.
3· Denied.
4· Denied.
5· Denied.
6. Denied.
7· Denied
8. Denied.
9· Denied.
10. Denied
11. Denied
12. Denied.
This 1<) daYOf ___ S_R_-t=-_--II----, 2010.
FREDERICK J. ATTORNE
. A. Greene, Esq. Georgia Bar No. 105227
IN THE STATE COURT OF GWINNETT COUNIY STATE OF GEORGIA
MIDLAND FUNDING LLC, ASSIGNEE OF CHASE BANK (USA), N.A.,
Plaintiff,
vs.
JILL SHERIDAN
Defendant.
CIVIL ACTION FILE NO. 10-7271-4
RULE 5.2 CERTIFICATE
The undersigned counsel for Plaintiff, Daniel A. Greene, hereby certifies
that a true and correct copy of PLAINTIFF'S RESPONSES TO
DEFENDANT'S FIRST INTERROGATORIES and REQUEST FOR
ADMISSIONS has been served upon the Defendant by depositing the same in
the U.S. Mail affixed with sufficient postage to assure delivery, to the following
address:
JILL SHERIDAN
3266 STONEWALL DRIVE
KENNESAW, GA 30152
This l.S.- day of ----~~--I+-_+- 2010.
Daniel A. Greene, Esq. Georgia Bar No. 105227
IN THE STATE COURT OF GWINNETT COUN1Y STATE OF GEORGIA
MIDLAND FUNDING LLC, ASSIGNEE OF CHASE BANK (USA), N.A,
Plaintiff,
vs.
JILL SHERIDAN
Defendant.
CIVIL ACTION FILE NO. 10-7271-4
RULE 5.2 CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing RULE 5.2
CERTIFICATE was this day served upon the Defendant by depositing the same in
the U.S. Mail affixed with sufficient postage to assure delivery to the following
address:
JILL SHERIDAN
3266 STONEWALL DRIVE
KENNESAW, GA 30152
. This 1.5..- day of_---'~~,-----/_
aniel A Greene, Esq. Georgia Bar No. 105227
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