DEFENDANTS FIRST REQUEST FORPRODUCTION

IN THE MGISTRATE COURT OF FULTON COUNTY

STATE OF GEORGIA

DEFENDANT’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

TO: MCREF DUNWOODY PRESERVE d/b/a THE PRESERVE AT DUNWOODY

You are requested pursuant to O.C.G.A. § 9-11-34(c) to produce the documents indicated below (by the corresponding check mark) for inspection and copying by the Defendant, within 30 days from the date of this request.

INSTRUCTIONS AND DEFINITIONS

1. “You” or “your” refers to Plaintiff(s) herein and to all other persons acting or purporting to act on behalf of Plaintiff(s), including agents and employees.
2. “Communications” shall mean all inquiries, discussions, conversations, negotiations, agreements, understandings, meetings, telephone conversations, letters, correspondence, notes, telegrams, telexes, advertisements, facsimiles, e-mail, or other forms of verbal and/or communicative intercourse.
3. “Documents” shall mean all written or graphic matter of every kind or description, however produced or reproduced, whether draft or final, original or reproduction, signed or unsigned, and regardless of whether approved, signed, sent, received, redrafted, or executed, including but not limited to: written communications, letters, correspondence, facsimiles, e-mail, memoranda, minutes, notes, films, recordings of any type, transcripts, contracts, agreements, purchase or sales orders, memoranda of telephone conversations or personal conversations, diaries, desk calendars, interoffice communications, reports, studies, bills, receipts, checks, checkbooks, invoices, requisitions or material similar to any of the foregoing however denominated, by whomever prepared, and to whomever addressed, which are in your possession, custody or control.
4. “Persons” means an individual, corporation, partnership, trust, association, company, organization, or any form of a business or commercial entity.

• For purposes of this discovery request “Identify” is defined as the following:
  • when used with respect to an individual, means to state (a) their name; (b) business affiliation and official title and/or position; and (c) their last known residential and business address.

• when used with respect to a document, means to state (a) the type of document (e.g. letter, memorandum, hand-written note, facsimile, e-mail) (b) its date of origin or creation; (c) its author and addressee; (d) its last known custodian or locations; and (e) a brief description of its subject matter and size. In lieu of identifying any document(s), you may attach a copy of it to your answer, indicating the question to which it is responsive.
  • when used with respect to a company or other business entity, means to state, (a) the company’s legal name, any former names, and the name under which it trades or does business; (b) the address of its principal place of business; and (c) the identity of its chief executive officer.
• “Relate to” means consist of, refer to, reflect or be in any way logically connected with the matter discussed.
• The period of time encompassed by these requests shall be from the date of the alleged accident to the date of answering, unless otherwise indicated. Note, this request is continuing up to and at the time of trial.
• For purposes of the Rule, a statement includes:
  • A written statement, signed or otherwise adopted or approved by the person making it, or
  • A stenographic, mechanical, electronic, videographic or other recording, or a transcript thereof, which is a substantially verbatim recital of an oral statement by the person making it and contemporaneously recorded.

DOCUMENTS AND THINGS TO BE PRODUCED

1. Any and all documents or receipts reflecting the funds provided to you directly or indirectly by the Defendant, together with copies of expense accounts submitted by you and/or on your behalf, from the date the Defendant entered the premises.
2. Any and all monthly statements, receipts and records of all utility service charges account held, used or maintained by you individually and/or jointly
3. with any other or others from the date the Defendant entered the premises.
4. Any and all bills related to utility and service charges maintained by you
5. individually and/or jointly with any other or others from the Defendant entered the premises.
6. Any and all documents, memoranda, closing statements or writings relating to utility and service charges from the date the Defendant entered the premises.
7. documents, memoranda, closing statements or writings demonstrating the formulas and/or methodologies used to calculate utility and service charges from the date the Defendant entered the premises.
8. Any and all audited documents, memoranda, closing statements, statements of accounts, income and expenditure statements or writings demonstrating income and outgoings of the Defendant’s utility and services payments received by the Plaintiff from the date the Defendant entered the premises
9. Any and all copies of any financial statements prepared by an accountant or any other person for you in relation to utility and service charges from the date the Defendant entered the premises.
10. All written statement(s) related to utility and service expenses and/or calculation of such utility and service expenses made to the Defendant from the date the Defendant entered the premises.
11. All investigation reports, documents, notes, internal memoranda, and correspondence created by the Plaintiff and its employees regarding or touching upon complaints made by the Defendant in relation to utility and service charges from the date the Defendant entered the premises.

Respectfully submitted,

/s/ Crystal Pendergrass

Dated: December 21, 2021 Crystal Pendergrass

1904 Summerbrook Drive,

Atlanta, GA 30350

Defendant.

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