EXHIBIT F

IN THE STATE COURT OF GWINNETT COUNTY

STATE OF GEORGIA

MIDLAND FUNDING LLC ASSIGNEE )

OF CHASE BANK (USA), N.A. )
)
Plaintiff, )
)
v. ) Civil Action No
) 10-07271-4
JILL SHERIDAN, )
)
Defendant )
 

DEFENDANT’S SECOND REQUEST FOR INTERROGATORIES,

REQUEST FOR ADMISSIONS, AND PRODUCTION OF DOCUMENTS
TO PLAINTIFF

COMES Now the Defendant JILL SHERIDAN, pro se and requests Midland

Funding, LLC to respond appropriately to the defendant’s discovery requests, as

the previous responses were incomplete, evasive, contradictive, and riddled with

“boilerplate” objections. Because the Georgia Civil Practice Act considers an

evasive or incomplete answer is to be treated as a failure to answer during

discovery, the defendant considers these responses as a failure to respond.

Each of the discovery responses from the Plaintiff were preceded by a list of

“General Objections” and it could only be left to the imagination which of these

“General Objections” apply to a specific request. Therefore, one could not

ascertain whether an answer is complete or whether further information or

documents would have been produced had it not been for the objections asserted.

The Defendant propounded sixteen INTERROGATORIES upon the Plaintiff

to which the response included a preamble of eighteen “General Objections”. The

Defendant propounded thirteen PRODUCTION OF DOCUMENTS requests upon

the Plaintiff to which the Plaintiff’s response included twenty “General

Objections”. The Defendant propounded twelve REQUESTS FOR ADMISSION

upon the Plaintiff to which the Plaintiff’s response included twenty one “General

Objections”.

Plaintiff is directed to serve its answers to Defendant’s Interrogatories,

Request for Admissions, and Request for Production of Documents to Defendant

on or before thirty (30) days from the date certified below to the Defendant’s

residence 3266 STONEWALL DR NW, KENNESAW GA 30152. If the plaintiff

cannot fulfill the defendant’s requests for discovery, it is requested by the

defendant that a meet and confer be scheduled to avoid any further waste of time

and resources.

REMAINING PAGES INTENTIONALLY OMITTED-

REQUESTS ARE EXACTLY THE SAME AS EXHIBITS "A" AND "C"

Page 2 of 15
 
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