sherisha lashelle lewis alabama divorce discovery 57-dr-2010-000440.00

7/28/2019 SHERISHA LASHELLE LEWIS ALABAMA DIVORCE DISCOVERY 57-DR-2010-000440.00

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AlaFileE-Notice

To: RAMEYBRIANANTHONY

[email protected]

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

[email protected]


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IN RE: THE MARRIAGE OF: * IN THE CIRCUIT COURT OF* RUSSELL COUNTY, ALABAMA

JOHN A. LEWI S, * FAMI LY DIVISIONPlaintiff, *

* CIVIL ACTION FILEvs. * NO: DR10-440

*SHERISHA L. LEWIS, *Defendant. *

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

COMES NOW SHERISHA L. LEWIS, Defendant, and propounds the following

'HIHQGDQWV 5HTXHVW IRU ,QWHUURJDWRULHV DQG 3URGXFWLRQ RI 'RFXPHQWV WR 3ODLQWLII JOHN A.

LEWIS, 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 terPVyRXDQGyRXUVas 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 Plaintiffs lawyer(s) and to any other person(s) acting pursuant

to Plaintiffs 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 terPGRFXPHQW 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 FILED1/26/2011 10:20 AMDR-2010-000440.00

CIRCUIT COURT OFRUSSELL COUNTY, ALABAM

KATHY S. COULTER, CLERK


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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 requiresupplemental answers and responses upon the receipt of additional information by thisPlaintiff or the3ODLQWLIIVDWtorney 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,

workeUVcompensation 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 youranswer a copy of your State and Federal Tax Returns for each year income wasreceived. 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 Answerlist 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


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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. Includeas part of your answer the names of all prescription medicationsreceived, 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. Includeas part of your answer any and all supporting documentationincluding 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. Include in your answerthe location of any of the aforementionedcircumstances 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? Include in your answerany information whatsoever madeknown 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 andlocations of same.


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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

includinga 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. Include in your answerthe 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.


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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 thiscause 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, tofile for this divorce. Include as part of your answer, the approximate dates of allacts or occurrences as well as the name and address of all persons that werewitnesses to same, and, if you are alleging fault on part of the Defendant, pleasestate 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.


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By: /S/

Brian A. RameyState Bar No. RAM016Attorney 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 Plaintiffwith the Clerk of the Courtusing the Case Management/Electronic Filing System (ALAFILE) which will send electronic

notification of such filing to the following:

Attorney for Plaintiff:

Jennifer B. Cooley1200 8

thAvenue

P.O. Box 463

Phenix City, AL 36868

This 26th day of January, 2011.

By:________/S/________________

Brian A. Ramey

Attorney for DefendantAL Bar No.: RAM016

P.O. Box 1002

Columbus, GA 31902-1002

(706) 536-9085


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IN RE: THE MARRIAGE OF: * IN THE CIRCUIT COURT OF* RUSSELL COUNTY, ALABAMA

JOHN A. LEWI S, * FAMI LY DIVISIONPlaintiff, *

* CIVIL ACTION FILE

vs. * NO: DR10-440*

SHERISHA L. LEWIS, *Defendant. *

RULE 5 (d)(D) CERTI FICATE

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

1. '()(1'$176 5(48(67 )25 INTERROGATORIES AND PRODUCTIONOF DOCUMENTS TO PLAINTIFF

by electronically filing the foregoing Rule 5(d)(D) Certificatewith the Clerk of the Courtusing 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 8th

AvenueP.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 1002Columbus, GA 31902-1002

(706) 536-9085