Non-Party Document Request

Scholle Law

ATTORNEYS AT LAW
6340 SUGARLOAF PARKWAY
SUITE 200
DULUTH, GEORGIA 30097
PHONE: 770.717.5100
FAX: 404.581.5970

cscholle@schollelaw.com
http://www.schollelaw.com

January 3, 2012

TO: A&R Iron Works
Attention: Records Custodian
552 Decatur Street SE

Atlanta, Georgia 30312

RE: Jennifer Garrison vs. Montag Realty Company, et al., 04-SV-3298

Job Name:The Verona
Location:2383 Bush Mill Road, Atlanta, GA 30339
Contact:The Montag Organization, c/o Eldon Warfield

Dear Sir or Madam:

Enclosed is a Request for Production of Documents concerning a construction work for Veranda Apartments. Veranda's owner is a Defendant in our case. I have attached a document which references the file to which I refer. This Request is sent pursuant to Georgia law, Section 9-11-34(c). This Georgia law allows parties to a lawsuit to request that persons, firms and corporations who have materials relevant to a lawsuit produce them for inspection and copying. I do not wish to inconvenience you, but on the contrary, hope that this procedure will save both your time and the time of the attorneys involved in this case. If this is a procedure that you have not been confronted with before, and if you have any questions, please feel free to call me.

We will see that you are compensated for the expenses of production and copying to the extent provided by law. Should your total charges exceed $50.00, please contact us prior to copying the records to obtain authorization for your charges.

Please note that this Request calls for production of your entire file, including any materials in your file which may have been provided to you by a third party. This Request is not limited in time, and includes all materials in your file from the date the first contact through the date of your response to this Request.

Attached to this request is a certification Affidavit, entitled “Response of a Non-Party to Request for Production of Documents”. You are required to complete this affidavit and return it with your response.

Thank you in advance for your cooperation in this matter.

Kindest Regards,
firm
P. Charles Scholle

Enclosure


FULTON COUNTY STATE COURT

STATE OF GEORGIA

JENNIFER GARRISON,

Plaintiff,

vs.

MONTAG REALTY COMPANY, LLC d/b/a VERONA APARTMENTS, THE REALTY FUND III, L.P. and JOHN DOES 1-5,

Defendants.

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JURY TRIAL DEMANDED

CASE NUMBER: 04-VS-070909-C



REOUEST FOR PRODUCTION OF DOCUMENTS TO NON-PARTY

TO: A&R Iron Works
Attention: Records Custodian
552 Decatur Street SE
Atlanta, Georgia 30312

Pursuant to Section 34(c) of the Civil Practice Act, you are hereby requested to produce the following documents and other evidence for inspection and copying by Plaintiff’s attorneys, Law Offices of Scholle Law, 6340 Sugarloaf Parkway, Suite 200, Duluth, Georgia 30097 within thirty (30) days after service of this request.

In lieu of the production at the time and place stated above, you may attach true and correct copies of the requested materials to the Affidavit which certifies to their authenticity and as to the number of pages provided. Said certification has been attached hereto and is to be returned to the Law Offices of Charles Scholle, Attention: Charles Scholle at the address listed above.

You are requested to produce the following documents:

1.

Your entire job file regarding the above-referenced customer, including but not limited to any photographs, correspondence, emails, documents or diagrams, all documents in your possession.

2.

Any and all photographs taken by you or your representatives with regard to the above-referenced file.

3.

Any other evidence or tangible things related to this job, customer or estimate.

This _______________ day of _______________, ____________.

________________________
P. Charles Scholle
Attorney for Plaintiffs
Georgia Bar Number 629736

Scholle Law
6340 Sugarloaf Parkway
Suite 200
Duluth, Georgia 30097
(678)775-6830


FULTON COUNTY STATE COURT

STATE OF GEORGIA

JENNIFER GARRISON,

Plaintiff,

vs.

MONTAG REALTY COMPANY, LLC d/b/a VERONA APARTMENTS, THE REALTY FUND III, L.P. and JOHN DOES 1-5,

Defendants.

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*

*

*

*

*

JURY TRIAL DEMANDED

CASE NUMBER: 04-VS-070909-C



RESPONSE OF A NON-PARTY TO REOUEST FOR PRODUCTION OF DOCUMENTS

TO: A&R Iron Works

Attention: Records Custodian
552 Decatur Street SE
Atlanta, Georgia 30312

COMES NOW, _________________________________, and responds to Plaintiff's Request for Production of Documents to a Non-Party served pursuant to Section 34 of the Civil Practice Act as follows:

Please indicate the appropriate response below:

( ) Copies of the requested materials have been attached.

( ) The material requested will be produced at the designated address; or

( ) The material requested do not exist.

AFFIDAVIT

Personally came before me, the undersigned officer, duly authorized to administer oaths, _________________________ who upon being duly sworn, states that (s)he is the custodian of these records and that the copies attached hereto are true copies and that there are ______ pages that have been attached and constitute the entire file materials requested.

THIS ____________ DAY OF ______________, ____________.



Signature________________________

Sworn to and subscribed before me
This _____ day of ________, _________.



_________________________
NOTARY


FULTON COUNTY STATE COURT

STATE OF GEORGIA

JENNIFER GARRISON,

Plaintiff,

vs.

MONTAG REALTY COMPANY, LLC d/b/a VERONA APARTMENTS, THE REALTY FUND III, L.P. and JOHN DOES 1-5,

Defendants.

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*

*

*

*

*

*

JURY TRIAL DEMANDED

CASE NUMBER: 04-VS-070909-C



CERTIFICATE OF SERVICE

I, P. CHARLES SCHOLLE, hereby certify that I have this day served the foregoing Non-party Request for Production upon the proper party or parties by depositing a copy of same in the United States Mail having sufficient postage thereon, addressed as follows:

Brenda Thomas
Thomas & Kane
3460 Chamblee-Dunwoody Way
Atlanta, Georgia 30341

This _______________ day of _______________, ____________.

________________________
P. Charles Scholle
Attorney for Plaintiffs
Georgia Bar Number 629736

Scholle Law
6340 Sugarloaf Parkway
Suite 200
Duluth, Georgia 30097
(678)775-6830

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