Professional Documents
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Amendedn Interrogatory Response
Amendedn Interrogatory Response
Goldman v. Eberly
16CV1860-9
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Plaintiff,
v.
ALLISON EBERLY
Defendant.
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Goldman v. Eberly
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Goldman v. Eberly
request, memorandum, and any other legal document associated with this civil
action.
Interrogatory No. 2: For each and every instance of libel or slander you
are claiming in the Lawsuit, please indentify [sic]: a.) The specific statement that
you allege is libelous or slanderous; b.) The identify of any and all non-party(s)
who heard or read the statement; c.) The date of the statement; d.) Whether the
statement was oral or in writing (including electronic); e.) Any and all documents
that evidence the statement; f.) Any and all facts you allege prove that the
statement was false.
Response to Interrogatory No. 2:
Interrogatory No. 3: Please identify any and all monetary damages you
are seeking in the Lawsuit and for each amount claimed, please describe how you
calculated it.
Response to Interrogatory No. 3: Subject to and without waiver of the
foregoing objections, Plaintiff states that the information sought by the Defendant
was previously provided within the pleadings when Plaintiff filed his Amended
and Redacted Complaint for Damages with this Court on February 29, 2016,
service of which was perfected upon the Defendant by U.S. certified mail.
Count II (22) of the pleadings identifies the compensatory damages sought
by Plaintiff, as well as how the amounts were reached, and states as follows:
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Goldman v. Eberly
Jeff A. Anderson, Gina E. Cadieux, George Hays E., and Michael B. Hingerty, Work Product Doctrine,
68 Cornell L. Rev. 760 (1983)
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required to disclose his legal research, opinions, or theory of the case to the
Defendant.
Interrogatory No. 5: Please identify any and all documents that you
allege support your claims in the Lawsuit.
Response to Interrogatory No. 5: Plaintiff objects to this interrogatory as it
is inappropriate to request any and all materials which might reveal the trial
strategy of Plaintiff in acting as his own attorney. Plaintiff objects to this
interrogatory, as it would be more appropriate as a request for the production of
documents. Subject to and without waiver of the foregoing objections, Plaintiff
states any and all documents will be provided within his document production per
Defendants Requests to Produce, under Request No. 1.
Interrogatory No. 6: Please identify any and all felonies that you have
been convicted of in the last twenty years.
Response to Interrogatory No. 6: Plaintiff has never been convicted of a
felony.
Interrogatory No. 7: Please state your work employment for the past ten
(10) years, giving the name and address of each employer, the period of each
employment, the general nature of the job, and the rate of pay.
Response to Interrogatory No. 7: Plaintiff objects to this interrogatory as it
is not reasonably calculated to lead to the discovery of admissible evidence. There
is no way that the Plaintiffs work history can provide any insight into and/or
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Goldman v. Eberly
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O.C.G.A. 24-9-67: The opinions of experts on any question of science, skill, trade or like
Schafer v. Time, Inc., U.S. Court of Appeals, Eleventh Circuit; No.96-8730. (June 8 1998). In an
action for defamation or libel, however, the issue of the plaintiff's reputation and character scarcely can be
avoided because the plaintiff typically seeks to recover compensation for damage to his or her
reputation.
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Interrogatory No. 13: Please identify each and every witness that you
expected [sic] to call pursuant to O.C.G.A. 24-7-701 to provide lay opinion
testimony at any hearing or trail in the Lawsuit.
Response to Interrogatory No. 13: Subject to and without waiver of the
foregoing objections, to the extent he understands the interrogatory, Plaintiff
intends to call/subpoena the following witnesses to depose and later provide lay
opinion testimony 5 on the stand: Pamela Simons; Melissa Miller; Cassie Apley;
Carol Lunsford. This list is subject to change at any time, based on any and all
developments in the case that alter the legal strategy of the Plaintiff, acting as his
own attorney. In the event of a change, Plaintiff will inform Defendants legal
counsel within ten (10) business days after the change is formalized.
Interrogatory No. 14: For each witness identified in your response to
Interrogatory No. 13, state the following: a) the subject matter on which the
witness is expected to testify; b) the substance of the facts, data, opinions and
mental impressions to which the witness is expected to testify; and c) a summary of
the grounds for each opinion.
Response to Interrogatory No. 14: Plaintiff objects to this interrogatory as
it seeks information that is only mandatory to disclose in terms of expert
witnesses, pursuant to GA Code 9-11-26 (2015), not lay witnesses.
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Plaintiff intends to either disclose his list of witnesses not providing lay opinion, including affiants, only
first hand accounts of personal evidence, within the Pre-Trial order. If compelled to do so by this court,
the latter will be protected, confidential information, and marked for Attorney Eyes Only (AEO).
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Interrogatory No. 15: Please identify any person having knowledge of the
facts discussed in your responses to these interrogatories, stating as to each that
persons name, address, current employer and a brief description of the relevant
matters within that persons knowledge.
Response to Interrogatory No. 15: Fearing retaliation, and at the request of
several of his witnesses, based upon the Defendants reputation for being generally
and habitually dishonest, Plaintiff objects to this interrogatory as it could possibly
lead to witness tampering.
_________________________
Dylan Goldman, Plaintiff, Pro Se
3106 Summit Lake Drive
Stone Mountain, GA 30083
(404) 989-3868
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