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Plaintiff,
CIVIL ACTION FILE
vs. NO. 10-7271-4
JILL SHERIDAN
Defendant.
GENERAL OBJECTIONS
grounds set forth in paragraphs "A" through "R" below. All general objections
and no response contained herein shall be interpreted as limiting in any way the
Interrogatories to the extent they exceed the scope permitted by O.C.G.A. § 9-11-
26 and § 9-11-33.
materiality or any other objections that would require the exclusion of any
testifying in Court.
any Interrogatory.
they are not reasonably calculated to lead to the discovery of admissible evidence.
does not put in issue or constitute the affirmative use of the advice of counselor
and/or documents shall be returned to Plaintiffs attorneys, along with any copies
made thereof.
1. These responses are made without waiver of, and with preservation
of:
any further proceeding in this action (including the trial of this action) or
(b) The right to object to the use of any such responses, or the
(d) The right at any time to revise, correct, add to, supplement
and/ or amend any or all of its objections and responses to the Interrogatories to
1. Daniel Adam Greene, esq. 1427 Roswell Road, Marietta GA, 30062.
irrelevant to the subject matter or issues of this action, and not reasonably
calculated to lead to the discovery of admissible evidence, on the ground that said
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
irrelevant to the subject matter or issues of this action, and not reasonably
calculated to lead to the discovery of admissible evidence, on the ground that said
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
irrelevant to the subject matter or issues of this action, and not reasonably
calculated to lead to the discovery of admissible evidence, on the ground that said
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
upon the Plaintiff because of Defendant's failure to limit the request; and on the
ground that said request exceeds the permissible scope of discovery under the
Georgia Civil Practice Act. Subject to such objections, and without waiving same,
Defendant's opening of, and default on, the subject credit card, as well as the sale
sale of the account to Plaintiff and the account information supplied to Plaintiff
opening of and default on the subject credit card account. None of these
upon the Plaintiff because of Defendant's failure to limit the request; and on the
ground that said request exceeds the permissible scope of discovery under the
Georgia Civil Practice Act. Subject to such objections, and without waiving same,
Defendant's opening of, and default on, the subject credit card, as well as the sale
sale of the account to Plaintiff and the account information supplied to Plaintiff
opening of and default on the subject credit card account. None of these
irrelevant to the subject matter or issues of this action, and not reasonably
calculated to lead to the discovery of admissible evidence, on the ground that said
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
upon the Plaintiff because of Defendant's failure to limit the request; and on the
ground that said request exceeds the permissible scope of discovery under the
Georgia Civil Practice Act. Subject to such objections, and without waiving same,
Defendant's opening of, and default on, the subject credit card, as well as the sale
sale of the account to Plaintiff and the account information supplied to Plaintiff
opening of and default on the subject credit card account. None of these
irrelevant to the subject matter or issues of this action, and not reasonably
calculated to lead to the discovery of admissible evidence, on the ground that said
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
irrelevant to the subject matter or issues of this action, and not reasonably
calculated to lead to the discovery of admissible evidence, on the ground that said
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
to, or already in the possession of, Defendant. Subject to said objection and
irrelevant to the subject matter or issues of this action, and not reasonably
calculated to lead to the discovery of admissible evidence, on the ground that said
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
irrelevant to the subject matter or issues of this action, and not reasonably
calculated to lead to the discovery of admissible evidence, on the ground that said
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
irrelevant to the subject matter or issues of this action, and not reasonably
calculated to lead to the discovery of admissible evidence, on the ground that said
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
irrelevant to the subject matter or issues of this action, and not reasonably
calculated to lead to the discovery of admissible evidence, on the ground that said
request exceeds the permissible scope of discovery under the Georgia Civil
Practice Act.
This ( : ; day of - -- - l - - - f ' - - - - + - - I - - - f - ' 2010.
FREDERICK J.
ATTORNE