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STATE OF INDIANA ) IN THE MARION COUNTY SUPERIOR COURT

) SS: CRIMINAL DIVISION F08

COUNTY OF MARION ) CAUSE NO. 49F08-0811-CM-254608

STATE OF INDIANA, )
Plaintiff, )
vs. )
)
KAY KIM, )
Defendants. )

DEFENDANT’S RESPONSE TO STATE’S RESPONSE ON

DEFENDANT’S REQUEST OF INTERROGATORIES

Comes now the Defendant, Kay Kim, Pro Se filed her Defendant’s Response to State’s

Response on Defendant’s Request of Interrogatories of Mae Vera and Patricia Ladenthin filed on

April 28, ‘09 on this 29th Day of April, 2009 as follows and not limited to:

Deputy Prosecutor Andrew Wignall stated in his response as follow:

“Deputy Prosecutor Andrew Wignall object to Defendant’s Request for

Interrogatories of Mae Vera and Patricia Ladenthin. In support of its motion….. The proper

procedure for the collection of discovery in Marion County Criminal Courts is by deposition or

taped statement

1. Deputy Prosecutor Andrew Wignall failed to state the court and to the Defendant

that what “Law” exactly his is quoting as to proper procedure. Defendant, Kay Kim, Pro Se

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demand to know what Indiana law &/or rule Deputy Prosecutor Andrew Wignall is

referring/quoting.

2. Defendant, Kay Kim, Pro Se served/Requested Interrogatories to Mae Vera and

Patricia Ladenthin pursuant to Indiana law.

3. Furthermore, Mae Vera is not a State’s witness. Defendant, Kay Kim, Pro Se has

every right to obtain relevant(s) evidence however I see it fits within boundary of the law and

Deputy Prosecutor Andrew Wignall has no right to interfere with my witness. Unless, Deputy

Prosecutor Andrew Wignall is intend to commit a criminal conspiracy with own witnesses,

other(s) and my witness(es).

4. However, if Deputy Prosecutor Andrew Wignall’s own State’s witness Patricia

Landenthin not to answer Defendant, Kay Kim, Pro Se’s written Interrogatories and prefer

depose by the Defendant, Kay Kim, Pro Se directly sitting across from the table and only on the

tape then he should have stated and let Defendant, Kay Kim, Pro Se and the court know what

would be acceptable form for me to accommodate at least 45 days before omnibus date.

5. Upon court’s deny of Defendant’s request of Interrogatories from State’s witness,

Patricia Ladenthin, Defendant, Kay Kim, Pro Se will file a “Notice of Intent to Depose” State’s

witnesses fromPatricia Ladenthin, Rhonda Heath and Linda Handlon.

6. Deputy Prosecutor Andrew Wignall totally misunderstood the law and

misinterpret the law. In his own response that proper collection of discovery is “…. by

deposition or taped statement….”. For his and court’s information, written interrogatories is one

of method of Deposition and Discovery.

7. Conduct of Deputy Prosecutor Andrew Wignall has no intention to find the truth

and for sake of justice. Further, Deputy Prosecutor Andrew Wignall meddling with Defendant’s

witness shows his criminal conspiracy intention against the Defendant, Kay Kim, Pro Se.

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WHEREFORE, Defendant Kay Kim, Pro Se respectfully requests that the Court to take

appropriate action against the Deputy Prosecutor Andrew Wignall for obstruction of justice

meddling with Mae Vera who is not a State’s witness and his criminal conspiracy intent against

the Defendant, Kay Kim, Pro Se for the record and deny Deputy Prosecutor Andrew Wignall’s

request. If the court to grant Deputy Prosecutor Andrew Wignall request is contrary to the law of

discovery and disclosure because Defendant’s request does not cause physical harm to the State’s

witness and it is relevant to the case. Furthermore, it will only expedite process.

Respectfully submitted

Dated: April 29, 2009 By:

Kay Kim, Pro Se

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been delivered to the
court F8 and prosecutor (‘box by F8 clerk) either by U.S. First Class Mail, FAX or server.

Kay Kim, Pro Se

4250 Village pkwy c e apt2.,
Indiana polis, IN 46254
Tel# 317-641-5977
DISTRIBUTION:
Prosecutor: NW Dist outgoing box in F08

Special Judge F08:ph317-327-3202, Fax317-327-1432, clk317-327-5665

ref 1: Special Judge Judith S. Proffitt

E643 City-County Building,

200 East Washington St.,

Indianapolis, IN 46204

f8clk 317-327-5665/3202, f8f# 317-327-1432

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ref 2: Andrew Wignall, Deputy Prosecuting Attorney, NW Dist.

3821 Industrial Blvd.,

Indianapolis, IN 46254

P#317-327-6652

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