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AlaFileE-Notice

To: RAMEYBRIANANTHONY
yemarb@yahoo.com
57-DR-2010-000440.00
NOTICEOFELECTRONICFILING
INTHECIRCUITCOURTOFRUSSELLCOUNTY,ALABAMA
ThefollowingdiscoverywasFILEDon1/26/201110:20:41AM
JOHNALEWISVS.SHERISHAL.LEWIS
57-DR-2010-000440.00
NoticeDate: 1/26/201110:20:41AM
KATHYS.COULTER
CIRCUITCOURTCLERK
RUSSELLCOUNTY,ALABAMA
RUSSELLCOUNTYJUDICIALCENTER
PHENIXCITY,AL36867
334-298-0516
kathy.coulter@alacourt.gov
I N RE: THE MARRI AGE OF: * I N THE CI RCUI T COURT OF
* RUSSELL COUNTY, ALABAMA
JOHN A. LEWI S, * FAMI LY DI VI SI ON
Plaintiff, *
* CI VI L ACTI ON FI LE
vs. * NO: DR10-440
*
SHERI SHA L. LEWI S, *
Defendant. *

DEFENDA1765(48(67)25,17(552*$725,(6$1'
PRODUCTI ON OF DOCUMENTS TO PLAI NTI FF

COMES NOW SHERI SHA L. LEWI S, Defendant, and propounds the following
DeIendant`s Request Ior Interrogatories and Production oI Documents to PlaintiII, JOHN A.
LEWI S, to be answered in accordance with the Alabama Rules of Civil Procedure (A.R.C.P.) to be
responded to under oath within thirty (30) days:
The following preliminary statement and definitions apply to each of the
Interrogatories hereunder and are deemed to be incorporated therein:

1. The terms 'you and 'yours as they are used herein refer to the Plaintiff and
include any and all agents, servants, and employees of the Plaintiff including but
not limited to the Plaintiff`s lawyer(s) and to any other person(s) acting pursuant
to Plaintiff`s direction and/or on her behalf in any way.

2. Any singular number and reference to the masculine gender shall include the
plural, the feminine, whichever shall be deemed correct.

3. The term person(s) shall include the singular and plural, and shall include any
natural person, corporation, entity, firm, association, partnership, group, joint
venture or other legal entity.

4. When you are required to provide the identification of a person or entity,
include:
a.. full name
b. address
c. telephone number

5. The term 'document means originals and copies of written, recorded and
graphic material including but not limited to correspondence, letters,
memoranda, drafts, notes, official records, lists, books, statements, commercial
statements, invoices, cancelled checks, previous bank statements, every type of
voice and image recording(s) and data compilation.

6. This discovery calls for information known to you and/or others who operate in
ELECTRONICALLY FILED
1/26/2011 10:20 AM
DR-2010-000440.00
CIRCUIT COURT OF
RUSSELL COUNTY, ALABAMA
KATHY S. COULTER, CLERK
your employ, including but not limited to your attorneys, accountants,
investigators operating on your behalf regardless of the entity actually employing
their services, all legal entities and actual persons working on your behalf and at
your control.

These interrogatories and requests shall be deemed continuing so as to require
supplemental answers and responses upon the receipt of additional information by this
Plaintiff or the 3ODLQWLIIVDWtorney subsequent to the original response.

1. State your complete name, age, residence address, drivers license number and
social security number.

2. List each and every location you have been employed in the past two years.
Include in your answer the address and phone number of each, as well as the name
of your immediate supervisor and reason for leaving said employment. Include the
amount received by you as a wage or salary, including tips, at each place of
employment.

3. Please list and describe all income from whatever sources, (including, but not
limited to, salaries, wages, commissions, bonuses, dividends, severance pay,
pensions, interest, trusts, annuities, capital gains, Social Security benefits,
workers` compensation benefits, unemployment insurance benefits, disability
insurance benefits, gifts, prizes, and preexisting periodic alimony) which you
currently and have received in the past three (3) years. Attach as part of your
answer a copy of your State and Federal Tax Returns for each year income was
received. Include in your answer all documents showing income including any
instrument used toward gaining an extension and all documents relied upon for
filing said returns or extensions.

4. List all income from whatever sources received by you from January 01, of this
current year, to date, and name said source. Please provide copies of your current
paystub and all profit and loss statements.

5. List each and every bank account; whether checking, savings, retirement, or other,
which you have maintained, had any interest or drawing authority, in whole or in
part, individually, jointly with another or with any business entity, or deposited
funds since the date of your marriage to the Defendant. As part of your Answer
list the account numbers, present balance, and largest balance of any account
maintained by you within the last five years. Provide a copy of each and every


check written by you on each and every account maintained by you in the past
three years.

6. Fully list all pharmacies you have used in the past three years to fill any/all
prescriptions issued in your name or the name of another who is under your control
and/or care. Include as part of your answer the names of all prescription medications
received, the dates, amounts, and reasons for same.

7. Please list each and every doctor, physician, counselor, psychiatrist, therapist and/or
psychologist you have seen for any purpose within the past five years. As part of
your answer, describe in detail the reasons for same and all prescription medication
that has been prescribed to you for any reason within said five year period.

8. Fully describe in detail all events in the past two years in which you claim the
Defendant has been physically abusive to you or caused you to be in fear for your
safety. Include as part of your answer any and all supporting documentation
including but not limited to reports, police reports, notes, memoranda, or other
papers or documents supporting the answer to this question. If you do not have the
information or requested items, please fully disclose where the above requested
information can be located.

9. Have you been questioned about, arrested for, or charged with any criminal offense
within the last two years? If you answered in the affirmative, fully list each and every
such instance and explain in detail the offense, the surrounding circumstances, and
the outcome. I nclude in your answer the location of any of the aforementioned
circumstances as well as the name of the Court in which any charges are pending,
and attach copies of all related police reports.

10. Have you ever used/hired a private investigator or any person acting as such or in such
a manner to follow or investigate the Defendant or any other person associated with
this case in any way? I nclude in your answer any information whatsoever made
known to you or any other person as a result of said investigation.

11. Provide the name, address, and telephone number of each and every individual,
whether male or female, minor or adult, with whom you have had any type of sexual
encounter or sexual relations and the dates of same, since the date of your wedding to
the Defendant.

12. Provide the name, address, and telephone number of each and every individual,
whether male or female, minor or adult, with whom you have had any type of
romantic meeting and/or been on any date or trip with, had any meal with, had a one-
on-one meeting with, confided in, and communicated via email or text messaging for
the past one (1) year. As part of your answer, list all approximate dates and
locations of same.





13. Please produce copies of any and all of your MySpace information and
communications, facebook information and communications and any other web-
based application in which you are a member or on which you have posted anything
about you, including copies of any and all pictures and correspondence- type
information in connection therewith for the past two (2) years.

14. Please list all real property which you own or in which you have any interest at the
present time, or retroactively during the term of your marriage to the Defendant.

15. Please list and describe all real and personal property which you have disposed of,
whether by sale, lease, or otherwise, in the past two years. Include in your answer the
names and addresses of such persons to whom said property was disposed, and the
amount(s) received from such disposition.

16. Please list and describe all personal property you removed from the house in
connection with your separating from the Defendant and leaving and moving out of
the marital residence, and the current location of all such property.

17. Please list each and every credit account which you have acquired in your name, the
name of the Defendant, or in your names jointly in the past two years. Please provide
a copy of each and every application which you have submitted with reference to same
including a copy of monthly billing statements for the past three years.

18. Produce evidence of any current debts which are yours either individually or
jointly with another.

19. Evidence of any transaction in which you are involved wherein money and/or
personally was loaned or given by you to an individual or entity for the preceding two
(2) years, as well a any evidence of any loan or gift made by you, whether business or
personal, for whatever purpose, for the preceding two (2) years.

20. List each and every medication which you currently take, whether prescription or
over the counter, and how often you take such medication. I nclude in your answer
the name of the prescribing physician and the reason for taking such medication.

21. List the names and addresses of any and all persons who have made/given any type
of written or verbal statement regarding this cause to you or anyone else regarding
any issue related to this case in any way. Please produce copies of any
written statements.

22. Have you ever been a party to a civil suit? If so, please state the names of all parties
involved, the case number, the location and the current status or outcome of same.
Please attach copies of any related court documents.






23. Please state whether you contend that your spouse committed any wrongdoing of any
nature during the term of your marriage. If so, state the nature of the alleged conduct,
giving in detail the facts and circumstances which support your allegation. Please also
include the name and addresses any witnesses to the same.

24. Produce any and all documents which you rely on as evidence in the defense of this
cause or in the prosecution of any counterclaim you intend to assert in this cause.

25. Please list each and every automobile or motor vehicle which you currently own,
possess, control, or drive, stating the make, model, and body style, and the owner of
said vehicle.

26. Please state whether you have ever hit, kicked, struck, cursed or directed abusive
language to your spouse. If you answered in the affirmative, fully describe in detail
all such instances.

27. Please describe in detail all events or occurrences which caused you the Plaintiff, to
file for this divorce. I nclude as part of your answer, the approximate dates of all
acts or occurrences as well as the name and address of all persons that were
witnesses to same, and, if you are alleging fault on part of the Defendant, please
state in detail the fault you claim on the part of the Defendant.

28. Please list in detail any property of the marriage that you claim is your separate
property.

29. State any and all facts and produce any and all evidence, of whatever kind or nature,
you contend supports the allegations made by you in Paragraph 22 of your Complaint
for Divorce, filed on December 21, 2010.

30. To the extent not stated in your foregoing response(s), state any and all facts and produce
any and all evidence and information in your possession, including copies of any and all
police/incident reports, concerning any allegations you have made against Defendant to
the police or any other government, public or private agencies, court of law, or any other
person or entity since your marriage to the Defendant.

31. Give the names and address of all witnesses whom you intend to all for any
purpose in the trial of this cause.

32. Produce copies of any and all documents, letters, files, records, diaries, cards,
recordings, statements and all other physical evidence (tapes, photographs,
electronic evidence, etc.) which you rely on as evidence in this cause and which
you intend to use in the preparation or trial of this cause.

33. Do you understand that these interrogatories are answered under oath, may be
used as material testimony in the event of a trial or hearing, and MUST be
updated if your foregoing responses change in any way.




By: /S/
Brian A. Ramey
State Bar No. RAM016
Attorney for Defendant

P.O. Box 1002
Columbus, Georgia 31902
(706) 536-9085



CERTIFICATE OF SERVICE

I hereby certify that on Janaury 26, 2011, I electronically filed the foregoing 'HIHQGDQWV
Request for I nterrogatories and Production of Documents to Plaintiff with the Clerk of the Court
using the Case Management/Electronic Filing System (ALAFILE) which will send electronic
notification of such filing to the following:

Attorney for Plaintiff:

Jennifer B. Cooley
1200 8
th
Avenue
P.O. Box 463
Phenix City, AL 36868


This 26th day of January, 2011.

By:________/S/________________
Brian A. Ramey
Attorney for Defendant
AL Bar No.: RAM016
P.O. Box 1002
Columbus, GA 31902-1002
(706) 536-9085






I N RE: THE MARRI AGE OF: * I N THE CI RCUI T COURT OF
* RUSSELL COUNTY, ALABAMA
JOHN A. LEWI S, * FAMI LY DI VI SI ON
Plaintiff, *
* CI VI L ACTI ON FI LE
vs. * NO: DR10-440
*
SHERI SHA L. LEWI S, *
Defendant. *

RULE 5 (d)(D) CERTI FI CATE

This is to certify that on January 26, 2011, I served a true and correct copy of the following:

1. DEFENDANT`S REQUEST FOR INTERROGATORIES AND PRODUCTION
OF DOCUMENTS TO PLAINTIFF

by electronically filing the foregoing Rule 5(d)(D) Certificate with the Clerk of the Court
using the Case Management/Electronic Filing System (ALAFILE) which will send
electronic notification of such filing to the following:

Attorney for Plaintiff:

Jennifer B. Cooley
1200 8
th
Avenue
P.O. Box 463
Phenix City, AL 36868

This 26th day of January, 2011.

By:________/S/________________
Brian A. Ramey
Attorney for Defendant
AL Bar No.: RAM016
P.O. Box 1002
Columbus, GA 31902-1002
(706) 536-9085

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