Technology Case - Plaintiff's Investigation and Discovery

IN THE STATE COURT OF FULTON COUNTY

STATE OF GEORGIA

CLARENCE PARKER,

Plaintiff,

v. CIVIL ACTION

FILE NO.: 11EV012007Y

WALTER GOODSON AND FEDEX NATIONAL, LTL, INC.,

Defendants.

PLAINTIFF'S RESPONSES TO FEDEX FREIGHT NATIONAL, LTL, INC.'S FIRST CONTINUINGINTERROGATORIES AND REQUEST FOR PRODUCTION

COMES NOW Plaintiff and responds to GA Farm Bureau's First Interrogatories and Request for Production of Documents as follows:

GENERAL OBJECTIONS

Plaintiff's investigation and discovery in this matter are continuing, and Plaintiff reserves the right to supplement, modify, or amend these responses, if necessary, to conform to facts and evidence. All rights of the Plaintiff are expressly reserved and nothing in the responses that follow is intended as or serves as a waiver of any and all rights of the Plaintiff consistent with the Georgia Civil Practice Act.

Plaintiff objects to these Interrogatories and accompanying instructions and definitions to the extent that they seek to impose any obligation on the Plaintiff, for supplementation or otherwise, beyond that required by the Georgia Civil Practice Act.

Plaintiff objects to these Interrogatories to the extent that they seek information or documents protected by the attorney-client privilege, the work product doctrine, or any other applicable immunity, or if they are vague or overly broad.

Subject to and without waiving the foregoing objections, Plaintiff responds to each interrogatory as follows:

RESPONSES TO FIRST INTERROGATORIES

1.

Please state Your full name, residence address, date of birth, social security number, occupation, including the name and address of Your employer, marital status, and name and address of your spouse.

Response:

Clarence Parker; Current Address is 5819 Belmont Ridge Circle, Lithonia, GA 30038; DOB: 05/11/1949; SSN: xxx-xx4123

2.

State Your residence addresses for the past ten (10) years.

3.

Please state for each of the last five (5) years Your income from wages, salaries, tips, and commissions; business or farm income; pension and retirement benefits; insurance proceeds and monetary settlements; government benefits or payments other than pensions; and any other source, identifying the source and the amount of income earned.

4.

For each of Your employers (including self-employment) for the last ten (10) years, please Identify the employer (including name and address) and Your job function for each employer.

5.

Identify with particularity and provide a description, including the dates thereof, for each physical or mental illness, injury, condition, disorder, infirmity, or abnormality experienced by You in the ten (10) years preceding The Incident. It is not a proper answer to this Interrogatory to attach medical records as a response.

6.

Identify each physician, chiropractor, therapist, or practitioner of any healing art consulted by You during the ten (10) years prior to The Incident, specifying for each the date of consultation and reason for the consultation.

7.

Identify every hospital or other health care facility in which You ever stayed overnight, specifying the condition requiring each stay and the dates on which each stay occurred.

8.

Identify the name and location of each high school, college, university, or technical school You attended and the dates thereof; all diplomas, degrees, or certificates held by You; and all professional or trade certificates or licenses held by You.

9.

Have You ever been arrested or charged with a crime of any kind? If yes, please Identify the month, day, and year of the arrest or charge, the entity (i.e. state or municipality, etc.) which made the arrest or charge, a description of the charges and/or the reason for arrest, and the disposition of the charges.

10.

Have You ever made a claim against any Person, corporation, insurance company, government agency, or other entity for personal injury, property damage, workers' compensation, or other matter? If yes, please Identify the name of the Person or entity against which the claim was made, the date on which the claim was made, the nature of the claim, and the disposition of the claim.

11.

Please Identify each Person with whom You had contact in the twenty-four (24) hours prior to The Incident.

12.

At the time of The Incident, please Identify from where You were traveling, Your intended destination, and the purpose of the travel.

13.

Please Identify the mobile telephone provider and corresponding mobile telephone number for any mobile phone used by You at the time of The Incident.

14.

For each policy of liability and health insurance which provided coverage at the time of The Incident, including any coverage available pursuant to Uninsured or Underinsured Motorist coverage, Identify the insurer; the named insured and policy number of each policy; and the limits of liability contained in each policy.

15.

Please Identify all Persons (including name, address, and telephone number) who, to your information, knowledge, or belief, witnessed The Incident.

16.

Please Identify all Persons (including name, address, telephone number, and nature of the Persons' knowledge) who, to your information, knowledge, or belief, have knowledge of the facts and circumstances of The Incident, the parties' involvement in The Incident, or You following The Incident.

17.

Have