Not legal advice
In preparation for a Motion to Compel Mr. Gaffney to answer the Interrogatories, I am sending him a Requestion for Admission. Unlike Interrogatories which require a judge's order to compel, Request for Admissions is automatically considered by the Court to be admitted or true, should the party being asked for admissions not respond in 30 days.
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COMMONWEALTH OF MASSACHUSETTS
Worcester Superior Court SS
C.A.
16-0288-B
**********************
Michael T.
Gaffney
Plaintiff
vs.
Gordon T.
Davis
Rosalie
Tirella
InCity Times
Defendants
*********************
DEFENDANT
GORDON T. DAVIS’ REQUEST FOR ADMISSIONS FROM PLAINTIFF, MICHAEL GAFFNEY
1. In Count 14 of your Complaint you claimed
injury due to pain and mental anguish.
2. You
did not provide any information about the nature or date of any pain or mental
anguish in your response to Defendant’s Interrogatory No. 4 .
“Please
describe the nature and date of all illnesses, accidents or injuries from which
you have suffered up to and including the present date.
Please
include any treatment for Mental Anguish and any other mental illness or
condition.”
3. In Count
14 of your Complaint you claimed that you have been injured in your business.
4. In
response to Defendant’s Interrogatory no. 1 you state that you are an attorney.
5. In
response to Defendant’s Interrogatory No. 5, you did not provide any
information about the clients who engaged your services as an attorney.
“Please
state the identity of any and all clients who engaged you as an “attorney” in
the past five years, including in your answer the address of any such person,
the date any such person hired you as an “attorney”, the purpose of your legal
counsel and the forum in which you practiced in the interest of any such
person.”
6. In your
response to Defendant’s Interrogatory no. 7 you provided no information about
any client who terminated your employment due solely to statements made by
Defendant.
7. In
your response to Defendant’s Interrogatory no. 8 you did not provide any
information about any potential client who denied you employment based solely
on the statements of the Defendant.
8. In
response to Defendant’s Interrogatory no. 9, you did not provide any
information about clients who terminated your employment or about potential
clients who declined your employment based on reasons other than statements
solely made by the Defendant.
9. In
your response to Defendant’s Interrogatory no. 11 you did not identify any
detailed or particular losses or damages.
10.
In
your response to Defendant’s Interrogatory no. 11 you claimed that the
Defendant is “clearly attempt to discover my clients and donors for the purpose
of harassing them.”
11.
In
response to Defendant’s Interrogatory no. 12 you did not provide any
information regarding your rate of compensation or your actual earnings.
12.
You
have read the Defendant’s Answers to your Complaint.
13.
You
have read the Defendant’s Third Affirmative Defense.
14.
In
response to Defendant’s Interrogatory no. 17 you provided no information about
your relationship to Turtleboy Sports or any of its employees.
15.
In
your response to Defendant’s Interrogatory no. 18 you provided no information
about any communication between you and Turtleboy Sports or any of its
employees regarding this instant case.
16.
You have read Defendant’s Alternate Second Affirmative
Defense.
17.
In your response to Defendant’s Interrogatory
no. 19 you do not deny that you were investigated by the Massachusetts Ethics
Commission and by OCPE regarding your professional practice.
18.
In
response to Defendant’s Interrogatory no. 20 you do not deny that Turtleboy
Sports and/or Aiden Kearney provided you with information about MOSAIC Cultural
Center.
19.
In response to Defendant’s Interrogatory no.
21 you do not deny that you and your friends used the terms “nigger, spic,
faggot, bitch”.
20.
In
your response to Defendant’s Interrogatory no. 22 the Black Law Dictionary
definition was for the term ‘capital.’
21.
In
your response to Defendant’s Interrogatory no. 22 you provided no definition
for the term “political capital”.
22.
In your response to Defendant’s Interrogatory
no. 23 you did not once use the term “political capital”.
23.
In
your Complaint you claimed injury and damages of one million dollars.
24.
In
your response to Defendant’s Interrogatory no. 24 you failed to detail or
provide a particular calculation of your injuries and damages that would add up
to one million dollars.
25.
In
your response to Defendant’s Interrogatory no. 24 you stated regarding the
Defendant “and his failed case against Turtleboy Sports.”
26.
In
response to Defendant’s Interrogatory no.26 you did not provide any information
about the people who have attended your fundraisers.
27.
In
response to Defendant’s Interrogatory no. 27 you provided no information about
the people who donated to your candidacies.
28.
You have read Defendant’s Alternate Fourth
Affirmative Defense.
29.
In response to Defendant’s Interrogatory no.
28 you did not deny you wrote the offensive social media posts about City
Councillor Sarai Rivera as seen in Worcester Magazine.
____________________
Gordon T. Davis Pro Se Defendant
CERTIFICATE OF SERVICE
I, Gordon T.
Davis, pro se Defendant hereby certify I have served the Plaintiff Michael T.
Gaffney a copy of the Defendant Gordon T. Davis’ Request for Plaintiff’s
Admission on June 15, 2016 by first class mail sent to
Michael T.
Gaffney, Esq.
416 Belmont
St. Suite 102
Worcester MA
01604
_________________
Gordon T.
Davis
Dated: June
15, 2016
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