Legal Advice- no way. These are the second set of Questions for Mr. Gaffney. I have it better to ask the Questions before seeking documents. Depending on the Answers to Questions the documents would be chosen to ascertain the veracity of the Answers.
OMMONWEALTH OF MASACHUSETTS
WORCESTER, SS SUPERIOR COURT 16-0288 B
********************************
Michael Gaffney, Plaintiff
Vs.
Gordon T. Davis *
Defendant
Vs.
InCity Times
Rosalie Tirella
Defendants *
********************************
DEFENDANT
SECOND SET OF INTERROGATORIES 25-28
TO
BE ANSWERED BY PLAINTIFF UNDER OATH
DEFINITIONS
A. IDENTIFY, OR
IDENTITY, when used in reference to:
1. PERSON OR INDIVIDUAL
shall mean to state his or her full name, present or last known residence
address (designating which), job title, employment address, business and
residence telephone numbers.
2. A firm, corporation
or other organization shall mean to state in full name, present or last known
address and telephone number (designating which), the legal for of such entity
or organization, and the IDENTITY of its chief executive officers.
3. DOCUMENT shall mean
to state the title (if any); the DATE; the IDENTITY of author, sender,
recipient, letter, memorandum, book, telegram, chart, etc.; or some means of
identifying it; and to IDENTIFY its present location and custodian;
4. LOCATION OR PLACE
shall mean to name a physical place in such detail as to satisfy Rule 34(b) of
the Massachusetts Rules of Civil Procedure, with respect to “reasonable
particularity”;
5. An ORAL communication
shall mean to state the DATE, subject matter, communicator, communicate, nature
of the communication (i.e., by telephone or face – to – face, etc.), whether it
was recorded in any way, and, if so, the manner in which it was recorded, and
the identity of any witnesses thereto;
6. COST OR AMOUNT shall
mean to state the total cost or amount and to itemize the cost or amount of
each component of the total, including but not limited to material equipment,
depreciation, salvage value, labor, taxes, overhead and profit;
7. STATE OR STATEMENT
shall mean to state in detail the DATE; the IDENTITY of the person making the
statement; the person to whom it is directed; the substance of the statement;
whether it was recorded in any manner, and if so, the manner in which it was
recorded and the IDENTITY of its present location and custodian; whether it was
verified by the person making the statement; the IDENTITY of any witnesses
thereto, and whether the statement was written or oral.
B. DATE shall mean the
exact day, month, and year, if ascertainable, or, if not, the best available
approximation including relationship to other events (indicating whether a DATE
is exact or approximate.
C. DESCRIBE shall mean
to specify in detail and to particularize the content of the answer to the
question and not just to state in summary or outline fashion, including but not
limited to stating each DATE, fact, including but not limited to stating each
DATE, fact, event, occurrence and IDENTIFYING each DOCUMENT and IDENTIFYING
each individual who can testify as to the alleged dates, facts, events, and
occurrences.
D. DOCUMENT shall mean
any physical embodiment of information, including but not limited to every
writing or record of every type and description that is of has been in the
possession, control or custody of the responding PLAINTFF or of which the
responding PLAINTFF has knowledge.
E. INCIDENT shall mean
the claim of the PLAINTIFF and the surrounding events and circumstances,
including any counterclaim filed or to be filed by the Defendants.
F. PLAINTIFF shall mean
MICHAEL T. GAFFNEY
A. DEFENDANT shall mean
GORDON T. DAVIS
INSTRUCTIONS
1. In answering each
interrogatory, please identify each individual who was a source of and
information provided in the answer.
2. The answer to the
interrogatories must include all information known to you and all persons
acting on your behalf or under your control, including but not limited to you
and all persons acting on your behalf or under your control, including but not
limited to you attorneys, investigators, insurance carriers and their
representatives. If you do not have
information to answer an interrogatory, you are under duty to make a reasonable
effort to obtain such.
3. These interrogatories
are to be deemed continuing in nature and it is hereby requested that any newly
discovered, corrected of additional information responsive to these
interrogatories be supplied as soon as is reasonably practicable upon receipt
thereof.
INTERROGATORIES
25.Please indicate whether the
mental anguish you allegedly suffered affected you relationship with your wife
and family in any way negative.
26. Please indicate everyone
and all people who attended any and all of your fundraising events for any and
all of your candidacies for City Council of Worcester MA.
27. Please provide everyone and all people who
contributed anything to your campaigns for City Councillor. Please include
contributors of money and in kind contributions.
28. Please refer to Worcester Magazine stories
attached to instant Questions. Did you author any of the social media posts
with your name appearing in the reference Worcester Magazine stories?
By
the Pro Se Plaintiff
Gordon
T. Davis
CERTIFICATE OF SERVICE
I, Gordon T. Davis, Pro Se Defendant,
hereby certify that I have this day served the foregoing Question 25-28 by mailing first class, postage prepaid to:
Michael
Gaffney
416 Belmont
St. Suite 102
Worcester,
Massachusetts 0l604
______________________________ ________________________
Gordon T.
Davis
May 4,
2016
