This is not legal advice
Mr. Gaffney has once again refused to answer my Discovery Interrogatories. He has responded with Objections. As he must know as he is an attorney, Objection only preserves his rights to Appeal, but does not excuse his refusal to answer the Questions. The only excuses for not answering are privilege and work product.
In order to file a Motion to Compel answers there is a requirement for a 9c conference.
Below is the correspondence sent to Mr. Gaffney.
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Dear Mr. Gaffmeu:
I recieved your responses to my Interrogatories. Unfortunately you did not answer the Questions as is rquired by Court rules. As you must know as an attonrney you are required to answer the Questions. You can state objections to preserve your rights to later appeal. The objections do not excuse your refusal to answer the Questions and it might be contempt of Court.
The only possible excuses you have for not answering the Questions are privillege and work product. You made not such claim in your responses to the Questions.
I called you today, June 10, 2016 to initiate a 9c conference on the matter in the hope of resolving or narrowing the issues. Please call me back as soon as can. I will try calling agian on Monday June 13, 2016.
Thank you for your attention to this matter.
Regards,
Goprdon T. Davis
Pro Se Defendant
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