Rogs To Zeeman Ocr¶

IN THE SUPERIOR COURT OF DEKALB COUNTY

STATE OF GEORGIA JONATHAN SWEATMAN,

Petitioner, v. SARAH ZEEMAN,

Respondent.

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CIVIL ACTION FILE NO.

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21CV9795

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PETITIONER’S FIRST INTERROGATORIES TO RESPONDENT

COMES NOW Petitioner Jonathan Sweatman (“Petitioner” or “Sweatman”), in the above

styled lawsuit, and pursuant to O.C.G.A. §§ 9-11-26 and 9-11-33, hereby serve Petitioner’s First

Interrogatories to Respondent Sarah Zeeman (“Respondent” or “Zeeman”) (the “Discovery Requests” or the “Interrogatories”).

Respondent is required to answer the following

Interrogatories separately, in writing, and under oath, within thirty (30) days from the date of

service of these Discovery Requests, all in accordance with Georgia Code Sections 9-11-26 and 9-11-33.

Each Interrogatory is addressed to the personal knowledge of Respondent, as well as the

knowledge and information of Respondent’s attorneys, agents, and other representatives. When an Interrogatory is directed to Respondent, the Interrogatory is also directed to each of the aforementioned persons.

Pursuant to Georgia Code Section 9-11-26, these Interrogatories are continuing so as to

require supplemental answers if Respondent obtains further or different information between the time her answers are served and the time of trial.

DEFINITIONS

When used herein, the terms “Respondent,” “you,” “your,” or any synonym thereof are intended to and shall embrace and include Defendant, and in addition to Respondent, the assigns, employees, agents, officers, or representatives of said Respondent or any other

person acting or purporting to act on behalf of Respondent, who are in possession of or may have obtained information for or on behalf of Respondent. “Respondent” refers to Sarah Zeeman. “Person” means any person and includes natural persons, private and public corporations,

partnerships, associations, joint ventures, sole proprietorships, firms and any other

business enterprise or entity of any description whatsoever. The term “or” means and/or.

“Document” means all written, printed, or recorded matter of any kind, wherever located,

including the originals and all non-identical copies, whether different from original by reason of any notation made on such copies or otherwise, graphics or oral records or representations of any kind within either of said Defendant’s possession, custody, or control.

“Communication” means any exchange or transmission of information whether oral, written, via electronic mail or by other means, and includes, but is not limited to, internal

and

external written,

oral,

telephonic,

electronic

mail,

or any

other inquiry,

representation, discussion, meeting, letter, correspondence, memorandum, note, newsletter, telegram, advertisement, speech, conversation, conference, e-mail or computer-generated message and includes any other document that evidences, refers, or relates to any such communication.

“Identify,” “identification,” “identity,” “describe,” “state,” and “set forth” mean:

1.

With reference to a natural person: a.

State the full name;

b.

State the present home address and business/employment address or the last

roe 2.

known such addresses if present addresses are unknown; and

State the present home and business telephone number or the last such

telephone numbers if present telephone numbers are unknown.

With reference to a “person” other than a natural person (“entity”):

a.

State the form of organization, and in the case of a corporation, the state of incorporation if within the United States, or the country of incorporation if outside the United States;

b.

State the address of principal place of business; and

c.

State the persons at the entity having personal knowledge of the matters with respect to which such entity is named.

3.

With reference to a document:

a.

State the date, type of document (e.g., letter, memorandum), author, addresses and recipients, title and file or identifying marking, its present

location or custodian, and all other means of identifying it with sufficient particularity to satisfy the requirement for its identification in a request for its production, pursuant to O.C.G.A. § 9-11-33; or alternatively annex to and incorporate by reference in the answers to these interrogatories a true and correct copy thereof; and

b.

If any such document was, but no longer is, in your possession or subject to your control, state the disposition that was made of it, by whom, the reason for such disposition and the date thereof.

4,

With reference to a communication:

a.

State the substance of the communication;

b.

State the identity of the persons between or among whom the

c.

communication was made;

State the identity of all persons present when the communication took place; and

d.

State the date and time when the communication was made and the manner in which it occurred (e.g., meeting, telephone conversation).

The terms “refer to” or “relate to” shall mean directly or indirectly, evidencing, consisting of, reporting on, with respect to, showing or indicating knowledge of, pertaining to, mentioning, describing, containing, disclosing, summarizing, rephrasing, or constituting a stated matter, fact, or thing.

The term “constitute” means in any way embodying, representing, exemplifying,

signifying, or being equivalent or equal to the subject matter or the document inquired

about.

The term “sent” means transmitted in any way including, without limitation, hand delivery, mail, fax, courier, dropping off at a designated location, electronic transmission, or any other method by which information is communicated between one person or entity and another.

The term “received” means obtained in any way including, without limitation, hand delivery, mail, fax, courier, picking up at a designated location, electronic transmission, or any method by which information is communicated between one person or entity and

another. The term “Petition” refers to the Verified Petition for Equitable Relief filed by Petitioner on November 12, 2021.

Any word not defined in this section shall have the same meaning as commonly used in

the English language.

INSTRUCTIONS

Petitioner intends to discover your computer data. Accordingly, Petitioner demands that you preserve all of your electronic data related to the subject matter of these Interrogatories and maintain the layout and configuration of your computer systems until Petitioner and you reach a complete agreement and understanding regarding the preservation of electronic data. You are prohibited from initiating or performing any activity that would or might result in the loss of electronic data, e.g., data compression

rotation, destruction, erasure of data, either on-line or off-line defragmenting any hard drives or purging any directories related to the subject of this litigation. This notice applies to any computers within your custody or control including servers, personal computers, mini-computers, laptop computers, notebook computers, palm computers, personal digital computers, main frames or other equipment.

Whenever the conjunction “and” is used, it is also to be interpreted disjunctively, and conversely, when the disjunctive “or” is used it is also to be interpreted conjunctively. The present tense of a verb includes past tense and vice versa, use of the singular includes

the plural and vice versa, and use of the masculine gender includes the feminine gender and vice versa.

If any information, communication or document is withheld under claim of privilege, identify for each such item of information, communication, or document the person(s) with personal knowledge of the information withheld, the parties to any communication withheld, the author(s) and recipient(s) of any document withheld, each person to whom a copy (copies) of any such document was furnished, the date(s) and subject matter of any information, communication or document as to which a privilege is claimed, and the

nature of the privilege claimed as well as the basis for such claim.

E.

All responses which refer back to previously stated responses or answers (“supra”) shall explicitly designate the number and, if applicable, the subsection of each previous response or answer relied upon.

SPECIFIC INTERROGATORIES

The interrogatories to be answered by you are as follows: Interrogatory No. 1

Identify all persons having knowledge of the claims made and/or defenses raised by you in this case and provide a brief summary of the knowledge of said persons and the last known address and telephone number for said persons. Interrogatory No. 2

Identify each document requested in Petitioner's First Request for Production of Documents which you are withholding from production. For each such document, state the specific grounds upon which each such document is being withheld. Interrogatory No. 3

Identify each person you expect to call as a fact witness at the trial of this action and, for

each such fact witness, state the subject matter on which the witness is expected to testify. Interrogatory No. 4

Identify each expert witness whom you intend to call at any hearing and/or trial of this

case. As for each such expert, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which each expert is expected to testify, a

summary of the grounds for each such opinion of each expert, all documents provided to or reviewed by each expert in preparation for his or her testimony or in reaching his or her opinions, and all written reports created by each expert related to this case.

Interrogatory No. 5

State all facts and circumstances and identify all documents in support of your denial in response to paragraph 10 of the Petition. Interrogatory No. 6

State all facts and circumstances and identify all documents in support of your denial in response to paragraph 13 of the Petition.

Interrogatory No. 7