ELECTRONICALLY FILED
`COURT OF COMMON PLEAS
`Tuesday, May 05, 2015 4:17:01 PM
`CASE NUMBER: 2014 CV 06581 Docket ID: 28304767
`GREGORY A BRUSH
`CLERK OF COURTS MONTGOMERY COUNTY OHIO
`
`
`
`Certification Page
`
`State of Ohio
`
`County of Montgomery
`
`Todd K. Hicks being fist duly cautioned and sworn, says that he has read the above mentioned
`
`Statement and that he has personal knowledgeof the facts contained in the responses, and that
`
`
`
`= JAIME GRAHAM,Notary Public
`= In and for the State of Ohio
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`MEMORANDUM IN SUPPORT
`
`STATEMENT OF THE CASE AND STATEMENT OF FACTS.
`
`This is a civil action wherein Plaintiff is seeking a money judgment against Defendant. Plaintiff
`
`filed its complaint on November24, 2014, alleging that Plaintiff and Defendant entered into a
`
`written week to week COD contract whereby Plaintiff would supply linen rental services to
`
`Defendant Louie’s Taphouse and Grill, Inc which would pay for those week to week COD
`
`services. Plaintiff alleges Defendant Todd K. Hicks signed the contract as personal guarantor.
`
`Defendant Louie’s Taphouse and Grill, Inc. went out of business sometime in the summer of The
`
`exact date is unknown to Mr. Hicks as he was no longer apart of Louie’s Taphouse and Grill.
`
`Economy Linen & Towel Services never attempted to contact Todd Hicks via USPS or
`
`Telephone. The first Todd K. Hicks learned that Economy Linen claimed a balance was
`
`outstanding is when he received notice of the Law Suite from Plaintiff's Attorney.
`
`Mr.Hicksdid receive the Plaintiffs Requests for Admissions and Interrogatories from Plaintiffs
`
`Attorney on or about March 23 via regular USPS mail.
`
`Mr. Hicks then answered both the Admissions and Interrogatories and returned them to
`
`Plaintiffs Attorney via regular USPS mail.
`
`Economy Linen & Towelservice is due no monies from Todd K. Hicks dueto the fact that the
`
`account was on a COD only. No credit application was everask fororfilled out by Louie’s
`
`Taphouse & Grill or Todd K. Hicks. If Economy Linen extended credit to Loute’s Taphouse &
`
`Grill or Todd K. Hicks they did so at their own risk and Todd K. Hicks should not be held liable
`
`for any money that may be owed Economy Linen.
`
`
`
`A copy of the Requests for Admissions and Interrogatories are attached to the statement.
`
`CONCLUSION
`
`For the foregoing reasons, Defendant respectfully requests that this court no grant Economy
`
`Linen & Towel Service a Summary Judgment and grant Todd Hicks an oral hearing on the above
`
`mentioned matter.
`
`Respectfully submitted,
`
`Todd K. Hicks
`2823 Lantz Rd.
`Beavercreek, Ohio 45434
`937-657-5725
`
`CERTIFICATE OF SERVICE
`
`I certify that I served a copy of the foregoing, in a hard copy version printed upon paper only
`upon:
`
`Jeffrey Jordan
`Attorney for Plaintiff
`P.O. Box 30863
`Gahanna, Ohio 43230
`
`
`
`CERTIFICATION PAGE
`
`STATE OF OHIO
`
`COUNTY OF MONTGOMERY
`
`Todd K. Hicks being first duly cautioned and sworm,states that the above mentionedis true and
`
`that he has personal knowledge of the facts contained in this response.
`
`
`
`Sworn to before me and subscribed in my presencethis at day of Mwe
`2015
`
`
`BowA
`
`
`Todd K. Hicks
`
`
`
`
`=: © JAIME GRAHAM, Notary Publ
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`= My Commission Expires Feb, 2, 2019
`
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`
`IN THE MONTGOMERY COUNTY COURT OF COMMONPLEAS, DAYTON,OHIO
`
`Economy Linen & Towel Service,Inc.
`
`Plaintiff
`
`Vv.
`
`:
`
`Louie’s Taphouse and Grill, Inc. et al.
`
`Defendants
`
`Case No. 2014 CV 06581
`Judge Huffman
`
`PLAINTIFF ECONOMYLINEN & TOWEL SERVICE,INC.'S REQUESTS FOR
`- ADMISSIONS TO DEFENDANT TODD K. HICKS
`
`ADMISSIONSTODEFENDAN!TUREADN!S
`
`Pursuant to Rule 36 of the Ohio Rules of Civil Procedure, Plaintiff Economy Linen
`
`& Towel Service, inc. requests that Defendant Todd K. Hicks respond to the following
`Requests For Admissions within twenty-eight (28) days of service hereof.
`
`INSTRUCTIONS AND DEFINITIONS
`
`As used herein the following terms have the meanings indicated below:
`
`The term “person” shall mean and include natural persons, governmental
`1.
`entities, proprietorships, corporations, partnerships, joint ventures and any other form of
`
`organization, entity or association.
`
`2.
`
`The term "document" shall mean any kind of written, printed, recorded or
`
`graphic matter, however produced or reproduced, of any kind or description, whether
`sent or received or neither, including originals, copies and drafts on both sides thereof,
`
`limited to papers, books,letters, correspondence, telegrams,
`and including but not
`cables, telex messages,financial statements, memoranda, notes, notations, work papers,
`transcripts, minutes,
`reports and recordings of
`telephone conversations or other
`conversations, or of
`interviews, or of conferences or other meetings, affidavits,
`
`statements, summaries, opinions,
`
`reports, studies, analysis, evaluations, contracts,
`
`
`
`agreements, journals, statistical records, desk calendars, appointment books, diaries,
`expense account records,
`lists,
`taoulations, summaries, sound recordings, computer
`printouts, data processing input and output, microfilms, all other records kept by
`electronic, photographic or mechanical means, and things similar to any of the foregoing,
`
`however denominated.
`
`The term "communication" shall mean the transmission of any verbal or
`3.
`nonverbal, written or non-written message, sign, symbol or behavior, and shall include
`the process by which such transmission occurs.
`refer to
`4.
`The terms “Defendant, “you”, and “your”, when used herein,
`Defendant Todd K. Hicks, as well as ali persons acting or purporting to act on behalf of
`Defendant Todd K. Hicks,
`including any attorney or other representative.
`REQUESTS FOR ADMISSIONS
`Do you admit that the documentattached as Exhibit A to the complaintin this case
`is a true and accurate copy of the original version of a document which you
`Signed, at the bottom right ofthefirst page, on or around March 13, 2014?
`ANSWER:
`_
`WE L FB ngv
`
`
`
`Do you admit that the original version of Exhibit A attached to the complaintin this
`
`case constitutes a contract, mutually enforceable at law by Plaintiff and you?
`
`a
`A Peres
`
`Do you admit that someorall of the terms of the contract between Plaintiff and
`
`you are described in Exhibit A attached to the complaint in this case?
`
`ANSWER:
`
`ADrws
`
`
`
`ofits
`Do you admit that Plaintiff performed and/or substantially performed all
`obligations under the original version Exhibit A attached to the compiaint in this
`case?
`
`ANSWER: ete gL.
`
`ver 7
`
`Do you admit that Plaintiff has tendered substantial performance of all of its
`
`obligations under Exhibit A attached to the complaintin this case?
`
`ANSWER:
`
`Da waif
`
`
`
`ofits
`Do you admit that Plaintiff performed and/or substantially performed all
`obligations under the original version Exhibit A attached to the complaint in this
`
`case?
`
`ANSWER:
`
`7
`
`De you admit that Plaintiff has tendered substantial performance of all of its
`
`obligations under Exhibit A attached to the complaint in this case?
`
`ANSWER: Dewef
`
`/
`
`
`
`6.
`
`Do you admit that Plaintife has only failed to perform underthe original version of
`Exhibit A attached to the compiaint
`in this case and/or tender substantial
`performance under circ*mstances where attempts to perform and/or tender
`substantial performance would be a futility?
`ANSWER:
`_
`NO .aL Ce nweF
`
`Do you admit that, on and after September 15, 2014, Defendant Louie's Taphouse
`and Grill, Inc. refused to accept Plaintiff's performanceofits obligations under the
`original version of Exhibit A attached to the complaintin this case?
`ANSWER:
`
`VO DL Fe wer
`
`
`
`Do you admit that Defendant Louie’s Taphouse and Grill, Inc. refused to pay for
`Plaintiff's performance of Plaintiff's obligations specified in the original version of
`Exhibit A attached to the complaint in this case at any time after September 15,
`
`2014?
`
`ANSWER:
`
`NWO ££
`
`ZBypeF
`
`Do you admit that the correct calculation of liquidated damages pursuantto the
`
`liquidated damages clause, contained in paragraph 20 of Exhibit A attached to the
`
`complaint in this case, results in the amount of $10,055.12?
`
`ANSWER: NO x “Ye 467
`
`
`
`10.
`
`Do you admit that Plaintiff's actual weekly billing amount to Defendant Louie’s
`Taphouse and Grill, Inc., on September15, 2014, was $86.31?
`
`ANSWER:
`
`(JO Zz 27s ever
`
`11.
`
`Do you admit that, on September 15, 2014, 233 weeks remained in the 60-month
`
`term specified in Exhibit A attached to the complaint in this case?
`
`ANSWER: 40 ZL Po res
`
`
`
`12.
`
`Do you admit that no one has paid to Plaintiff any amount of moneyfor liquidated
`damages pursuant to the liquidated damages clause, contained in paragraph 20 of
`Exhibit A attached to the complaintin this case?
`
`ANSWER:
`
`13.
`
`Do you admit that Defendant Louie's Taphouse and Grill, Inc. has failed to pay to
`Plaintiff
`invoices totaling $2,306.79, for linen rental services provided before
`September 15, 2014?
`
`ANSWER:
`
`
`
`14.
`
`Do you admit that Defendant Louie’s Taphouse and Grill, Inc. has failed to pay to
`Plaintiff $1,274.85 owed for customized and/or unreturned merchandise?
`
`ANSWER:
`
`jo = Ge pov:
`
`15.
`
`Do you admit that Defendant Louie’s Taphouse and Grill, Inc. has failed to pay to
`
`Plaintiff sales tax due in the arnount of $764.77?
`
`ANSWER:
`
`_
`veo LF Ve sv
`
`
`
`16.
`
`Do you admit that Defendant Louie’s Taphouse and Grill, Inc. owes to Plaintiff
`
`compensatory damagesin this case totaling $14,401.53?
`
`ANSWER:
`
`Me FT Lo nee.
`
`Respectfully submitted,
`JME——
`
`Jeffrey H. Jardan (0047296)
`Attorney for Plaintiff
`LAW OFFICE OF JEFFREY H. JORDAN
`P.O. Box 30863
`Gahanna, Ohio 43230
`(614)224-0813
`Fax (614)224-0842
`Email lawoffice@lawofficejhj.com
`
`CERTIFICATE OF SERVICE
`
`| certify that | served a copy ofthe foregoing, in a hard copy version printed upon
`paperand in an electronic version recorded upon a compact disc, upon:
`
`Todd K. Hicks
`2823 Lantz Road
`Beavercreek, Ohio 45434
`
`by ordinary United States mail, postage prepaid, this 43" day of March, 2015.
`[illfy ———
`
`JEFFREY H. JORDAN (0047296)
`
`
`
`EXtHBIT A /
`
`INTERROGATORIES
`
`NOTE: FOR YOUR RESPONSES 1) BE COMPLETE PLEASE READ AND FOLLOW
`THE INSTRUCTIONS AND DEFINITIONS LISTED ABOVE.
`
`Please identify yourself and each person who assisted you in preparing responses
`to the following Interrogatories and Requests for Production of Documents.
`
`(PLEASE USE THE DEFINITION OF “IDENTIFY’ GIVEN IN INSTRUCTIONS
`AND DEFINITIONSI.a. ABOVE: IN RESPONDING TO THIS INTERROGATORY.)
`ANSWER:
`
`Foor? hes
`
`E23 LoteFA 2bED
`
`Weaver CLECK, ofl SSYE-
`
`identify all
`matter.
`
`in the above-captioned
`lay witnesses whcm you may call at Trial
`(PLEASE USE THE DEFINITION OF “IDENTIFY” GIVEN IN
`
`INSTRUCTIONS AND DEFINITIONS La. ABOVE IN RESPONDING TO THIS
`
`INTERROGATORY.)
`
`
`
`ANSWER: fasOM heNpi-raa
`
`OVTS
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`E lowey Lreen Bn ancl fH ANRGER PURME LEKpoe)
`— Cover 7 Linen
`Coewtaal Wannabee Naw Nknous)
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`
`
`
`(a)
`
`Identify the expected subject matter of each lay witness’ testimony.
`
`ANSWER:
`
`Fe APPL ILaTIO Ww
`CREGIS fROCED IRE
`
`identify all expert witnesses wham you consulted, whom you may consult, and/or
`whom you maycall at Trial in the above-captioned matter.
`(PLEASE
`USE
`THE
`DEFINITION OF “IDENTIFY” GIVEN IN INSTRUCTIONS AND DEFINITIONS L.a.
`
`ABOVE IN RESPONDING TO THIS INTERROGATORY.)
`
`ANSWER:
`
`peer,
`
`oFflen
`
`Thwad PY StLF
`
`
`
`(a)_Identify the expected subject matter of each expert witness’ testimony.
`
`ANSWER:
`
`Liven SEAMECES
`
`(b) REQUEST FOR PRODUCTION OF DOCUMENTS
`Produce copies of any and all documents upon which each expert bases his/her
`
`opinion.
`
`ANSWER:
`
`orkrtw a7 A p*rn€
`
`
`
`(c) REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Attach a copy of each experts curriculum vitae (resume) and a list of any and all
`
`documents whether publicized or not which each expert contributed, co-authored, or
`
`authored.
`
`ANSWER:OeMeee AI de Fre’
`
`(d) identify and providealist of each and every time your expert(s) has/have been
`
`consulted for purposes of rendering an opinion,
`
`including for whom each expert was
`
`employed, the defendant's orplaintiff's name, case number, caption, and the date, time,
`
`and place the testimony or opinion wasgiven.
`
`ANSWER:
`
`VrKnbed ATths Firr€
`
`
`
`4.
`
`identify each document and/or exhibit which you may use or introduce into
`
`evidenceattrial in the above-captioned matter.
`
`(PLEASE USE THE DEFINITION
`
`OF “IDENTIFY” GIVEN IN INSTRUCTIONS AND DEFINITIONS 1.D. ABOVE IN
`
`RESPONDING TO THIS INTERROGATORY.)
`
`ANSWER:
`
`Ex fera7 A+ 46
`
`four PEF ay Plan TIFF
`
`(a) REQUEST FOR PRODUCTION OF DOCUMENTS
`Attach copies of all documents or exhibits described above or a list identifying
`
`each documentorexhibit.
`
`ANSWER:MLQead¥ frowt PER pod Donelarene
`
`
`
`if your response fo Request far Admissions No. 1 is a partial or complete denial,
`
`then please identify all facts and/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER:
`
`LZ Po wot Belsve fle Tb vet iT 48 One nad,
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Please produceoriginal versioris and/or copies of all documents which in any way
`
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`preceding Interrogatory No. 5.
`
`ANSWER:
`
`exhiaw Aa Bo Creerver BY [Lacrnrs rl
`
`
`
`if your response to Request for Admissions No. 2 is a partial or complete denial,
`then please identify all facts arid/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER:
`
`Voevat ent
`
`KS
`
`telCoytQWlesv€
`
`,
`
`REQUEST FOR PRODUCTION OF DOCUMENTSeeerrraaOTT
`Please produceoriginal versions and/or copies of all documents which in any way
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`
`
`preceding Interrogatory No. 7.
`
`ANSWER:
`
`EX Lb 07 Bev [pour teF ay (Ll AKTEF
`
`
`
`if your response to Request for Admissions No. 3 is a partial or complete denial,
`then please identify all facts and/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER:
`
`Avr 1 Go fa pete Te week LiorFraeeG-
`
`-
`
`|
`
`REQUEST FOR PRODUCTIONOF DOCUMENTSCeaeeNerannc
`Please produceoriginal versiors and/or copies of all documents which in any way
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`
`
`preceding Interrogatory No.9.
`
`ANSWER:
`CALOLLATION=ara
`
`Me pot Goriarine bow ile
`
`Barivel” nF
`
`
`
`ff your response to Request fcr Admissions No. 4 is a partial or complete denial,
`
`then please identify all facts and/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER:
`
`be En-T(nd PorwnerF .
`
`12.
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Please produceoriginal versions and/or copies of all documents which in any way
`
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`preceding Interrogatory No. 14.
`
`ANSWER:
`
`Gnilenats EX firar% A¢G EE of
`
`flantier Corblie
`
`
`
`if your response to Request for Admissions No. 5 is a partial or complete denial,
`
`then please identify all facts and/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER:
`
`EL Oni eae Pod urrtnTs
`(LattC Coon Planer FT
`
`of Lefh 07 AA E oF
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Please produceoriginal versions and/or copiesof all documents which in any way
`
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`preceding Interrogatory No. 13.
`
`ANSWER:
`
`Gales feel SIATED
`wbtl Go week
`
`pany Ferré Clomtaacl eas
`C67
`
`
`
`15.
`
`ff your response to Request for Admissions No. 6 is a partial or complete denial,
`
`then please identify all facts and/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER:
`
`_
`fl nm HEE Fee beP WaERIE ADere @ CrtEn4
`en
`16 ViFgn war? :
`
`16.
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Please produceoriginal versions and/or copies of all documents which in any way
`
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`preceding Interrogatory No. 15.
`
`ANSWER: SACE fel. SIAvEL Glee CrraaT pws fe sE£R
`So WEEE AP CestD Be GarcttleP LOOpotFFE
`
`bru wel Mikso~-
`
`
`
`17.
`
`If your response to Request for Admissions No. 7 is a partial or complete denial,
`then please identify all facts and/or circ*mstances which tend to support and/or
`contradict your denial.
`
`ANSWER:
`
`UMKMeare
`
`FE
`
`‘Fa v€
`
`oa
`
`e/bF,
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`Please produceoriginal versions and/or copies ofall documents whichin any way
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`preceding Interrogatory No. 17.
`
`ER:
`
`ANSW
`
`Gin n0r sea A #17
`
`
`
`If your response to Request for Admissions No. 8 is a partial or complete denial,
`
`then please identify all facts and/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER: WIh§ wet AT rile LockFIFE| Z Caw ror
`fay wiley Tears DPrtrivir OFF EnREY’.
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Please produceoriginal versions and/or copies of all documents which in any way
`
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`preceding Interrogatory No. 19.
`
`ANSWER:
`
`
`
`21.
`
`If your response to Request fer Admissions No. 9 is a partial or complete denial,
`
`then please identify all facts and/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`dM
`ANSWER:
`the Conve? wes COP Tlerthrr 79
`(se Fowl.
`DotFfarowb Xdpoe.
`
`22.
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Please produceoriginal versions and/or copies of all documents which in any way
`
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`preceding Interrogatory No.21.
`
`ANSWER:
`
`flnw7166's
`
`ko MO IF AVEE
`
`
`
`23.—If your response to Request for Admissions No. 10 is a partial or complete denial,
`
`then please identify all facts end/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER:
`
`6</¢:B OF fe
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Please produceoriginal versions and/or copies of all documents which in any way
`
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`preceding Interrogatory No. 23.
`
`ANSWER:
`
`foarwriees CxMeare a
`
`
`
`25.
`
`‘If your response to Request far Admissions No. 11 is a partial or complete denial,
`
`then please identify all facts and/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER:
`
`WY
`
`GAllS Heh SJaTrien 7s , @.0,D Fénor~s
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Please produce original versioris and/or copies of all documents whichin any way
`
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`preceding Interrogatory No.25.
`
`ANSWER:
`
`Mla He / Zh STATE RET of te Sacer (ler
`WtVe
`Jo wre. .
`
`
`
`27.
`
`If your response to Request for Admissions No. 12 is a partial or complete denial,
`then please identify all facts and/or circ*mstances which tend to support and/or
`contradict your denial.
`
`ANSWER:
`
`(6OvethenF
`Fan on$ COP
`£ ¥Mia)T A )
`$7ate 3 feelee~F wis Bt OB varit CAE0')7T 4 YbueP
`26 OnePr7 MAE poet§ vee FreeleO «wl.
`
`a
`
`a
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`Please produceoriginal versions and/or copies of all documents which in any way
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`preceding Interrogatory No. 27.
`
`ANSWER:
`
`HMawriets kin har? A
`
`
`
`29.
`
`{if your response to Request for Admissions No. 13 is a partial or complete denial,
`then please identify all facts and/or circ*mstances which tend to support and/or
`contradict your denial.
`
`ANSWER:
`
`(Lai w Fit §s
`
`guhoast #€
`
`30.
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`
`Please produce original versions and/or copies of all documents whichin any way
`mention, refer to, contain, and/or reflect the factual matter of your response to the
`
`preceding Interrogatory No. 29.
`
`ANSWER:
`
`{ln ww TEES OR MOB “7 A,
`SLTAFE peter F SF
`
`SALES
`
`fle Ff.
`
`
`
`31.
`
`If your response to Request for Admissions No. 14 is a partial or complete denial,
`
`then please identify all facts and/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER:
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Please produce original versions and/or copies of all documents whichrefer to,
`
`contain, and/or reflect any orall of the terms or conditions identified in your response to
`
`the preceding Interrogatory No. 31.
`
`ANSWER:
`JAC i fer SFATE Cow FakeG cAs
`Tenras CF Cor FrRLEF Has
`2. Ge
`
`or
`
`- oS
`LAEEK. Vo e/Ce
`
`
`
`33.—If your response to Request for Admissions No. 15 is a partial or complete denial,
`
`then please identify all facts and/or circ*mstances which tend to support and/or
`
`contradict your denial.
`
`ANSWER:Cow tamer erareD? PF? © So petrk¢P CG
`.
`Fectyr$ Fa FCFBARD areF
`fuasre Fh ExeAE Y
`
`34.
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`Please produce original versions and/or copies of all documents which refer to,
`
`contain, and/or reflect any or all of the facts which you identified in your response to the
`
`preceding Interrogatory No. 33.
`
`ANSWER:
`
`flate FIFES LifeiBlF A
`
`
`
`35.
`
`If your response to Request for Admissions No. 16 is a partial or complete denial,
`then please identify all facts and/or circ*mstances which tend to support and/or
`contradict your denial.
`
`/
`ANSWER:
`LComtw~ f Geet9 Bow TaceFeP yee ae
`of Fron £. Tiley 0lowe POOR Fe Fe SE.en
`Jens One GE.P.
`SE feo
`fenbe F
`€ a) fCMOP CRED m
`fitterrr OP Fe Stavied
`
`bee5S
`
`36.
`
`REQUEST FOR PRODUCTION OF DOCUMENTS
`
`
`Please produce original versions and/or copies of all documents which refer to,
`
`contain, and/orreflect any orall of the facts which you identified in your responseto the
`
`preceding Interrogatory No. 35.
`
`ANSWER:
`Exhsig A
`SeaterTS nwaArve
`2.6.2 - VEmae~s
`
`.aB
`
`L Feeley ELF?
`
`
`
`37.
`
`individual persons who signed their names on the original
`Please identify all
`version of Exhibit A to the Complaintin this case.
`(PLEASE
`USE
`THE
`DEFINITION OF “IDENTIFY” GIVEN IN INSTRUCTIONS AND DEFINITIONSLa.
`
`ABOVE IN RESPONDING TO THIS INTERROGATORY.)
`
`ANSWER:
`
`a0 hens
`
`26
`
`
