S vs G: Defendants' 1st Interrog

Staddon vs. Griever: Defendants' First Interrogatories to Plaintiffs

In the State Court of Athens-Clarke County, State of Georgia

Civil Action #ST-05-CV-0049

Main Text

Defendants herewith serve upon you the following interrogatories under the provisions of Section 33 of the Georgia Civil Practice Act (O.C.G.A. 9-11-93). You are required to answer these interrogatories separately and fully in writing under oath and to serve a copy of your answers on the undersigned, attorney for Defendant, hereinafter referred to as Defendant within thirty (30) days after service hereof.

NOTE A: When used herein the term "Plaintiff" or "you", or any synonym thereof, is intended to and shall embrace and include, in addition to said Plaintiff, counsel for Plaintiff and all agents, servants, employees, representatives, private investigators and others who are in possession of, or may have obtained, information for or on behalf of Plaintiff.

As used herein "document" shall mean but without limitation: every writing or record of every type and description that is or has been in the possession, control, or custody of Plaintiff or of which Plaintiff has knowledge including without