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EXHIBIT D

IN THE STATE COURT OF GWINNETT COUNlY


STATE OF GEORGIA

MIDLAND FUNDING LLC,


ASSIGNEE OF CHASE BANK (USA),
N.A.,

Plaintiff,
CIVIL ACTION FILE
vs. NO. 10-7271-4

JILL SHERIDAN
Defendant.

RESPONSE TO DEFENDANT'S REQUEST FOR ADMISSIONS

COMES NOW Plaintiff, by and through counsel, and responds to

Defendant's Request for Admissions, as set forth in the following manner below:

GENERAL OBJECTIONS

Plaintiff generally objects and responds to the Requests on the grounds set

forth in paragraphs "A" through "u" below. All general objections shall be

deemed to be continuing and shall be construed as supplementing each specific

objection and/or response to the Requests. No specific objection and no

response contained herein shall be interpreted as limiting in any way the scope or

effect of any general objection. Plaintiff objects generally to the Requests to the

extent they exceed the scope permitted by O.C.G.A. § 9-11-36.

A. Plaintiff objects generally to the Requests to the extent they

exceed the scope permitted by O.C.G.A. § 9-11-36.


B. Plaintiff objects generally to the Requests to the extent they

exceed the scope permitted by O.C.G.A. § 9-11-36 as there is no requirement that

responses to Requests for Admissions be verified.

C. Each response is subject to all objections as to relevance and

materiality or any other objections that would require the exclusion of any

statement herein if such statement were to be made by a witness present and

testifying in Court.

D. A response to any Request is not intended and should not be

construed to be a waiver by Plaintiff of all or any part of any objection to any

Request.

E. Plaintiff objects generally to the Requests to the extent they

assume facts that are inaccurate.

F. Plaintiff objects generally to the Requests to the extent they

are argumentative.

G. Plaintiff objects generally to the Requests to the extent they

are defective in form.

H. Plaintiff objects generally to the Requests to the extent they

are overly broad.

I. Plaintiff objects generally to the Requests to the extent they

are unduly burdensome.

J. Plaintiff objects generally to the Requests to the extent they

are oppreSSIve.

K. Plaintiff objects generally to the Requests to the extent they

are not reasonably calculated to lead to the discovery of admissible evidence.


L. Plaintiff objects generally to the Requests to the extent they

impose on it an unreasonable burden of inquiry.

M. Plaintiff objects generally to the Requests to the extent they

seek information that is subject to the attorney-client privilege, work product

privilege, or any other privilege or legal protection. The inadvertent or mistaken

production of information and/ or documents subject to the protections of the

attorney-client privilege, work product privilege, or any other privilege or legal

protection shall not constitute a general, inadvertent, implicit, subject matter,

separate, independent, or other waiver of such privilege or protection and does

not put in issue or constitute the affirmative use of the advice of counselor of any

privileged communications. All such inadvertently produced information and/or

documents shall be returned to Plaintiffs attorneys, along with any copies made

thereof.

N. Plaintiff objects generally to the Requests to the extent they

seek information that is of a confidential, proprietary, or trade secret nature.

O. Plaintiff objects generally to the Requests to the extent they

seek information that was prepared in anticipation oflitigation.

P. Plaintiff objects generally to the Requests to the extent they

are not properly limited as to time.

Q. Plaintiff objects generally to the Requests to the extent they

seek conclusions or request opinions or contentions that relate to the application

of law to facts.

R. Plaintiff reserves its right to supplement its objections and

responses to the Requests to the extent necessary and appropriate.


.--

S. Plaintiff objects to each Request as to which the information

known or readily obtainable by Plaintiff is insufficient to enable Plaintiff to admit

or deny the Request.

T. Plaintiff objects to each Request to the extent that it seeks

information that contains or reflects personal, proprietary or confidential

information, or other non-public business information.

U. Plaintiff objects to the Requests to the extent they do not

relate to the claims and defenses set forth in the pleadings.

RESERVATIONS

1. These responses are made without waiver of, and with preservation

of:

(a) The right to object to all Requests as to competency,

relevancy, materiality, confidentiality, privilege, and admissibility of the

responses, or the subject matter thereof, as evidence for any purpose in

any further proceeding in this action (including the trial of this action) or

in any other action;

(b) The right to object to the use of any such responses, or the

subject matter thereof, on any ground in any further proceeding in this

action (including the trial of this action) or in any other action;

(c) The right to object on any ground to any Request revised by

Defendant in response to any objection herein that a Request, or any part

thereof, is vague, ambiguous, overbroad, or unduly burdensome; and

(d) The right at any time to revise, correct, add to, supplement

or clarify any of the responses contained herein.


2. The following responses, and any further responses to the Requests,

or to their subject matter, are made expressly without acknowledgment of

materiality or relevance of the Requests, or that the Requests are in any way

reasonably calculated to lead to the discovery of admissible evidence.

SPECIFIC OBJECTIONS AND RESPONSES

1. Admitted. Plaintiff has provided all documents that are currently within

Plaintiffs possession, and will supplement discovery when appropriate.

2. Denied.

3· Denied.

4· Denied.

5· Denied.
6. Denied.

7· Denied
8. Denied.

9· Denied.

10. Denied

11. Denied

12. Denied.

This 1<) daYOf _ _ _ S_R_-t=-_--II----, 2010.

FREDERICK J.
ATTORNE

. A. Greene, Esq.
Georgia Bar No. 105227
IN THE STATE COURT OF GWINNETT COUNIY
STATE OF GEORGIA

MIDLAND FUNDING LLC,


ASSIGNEE OF CHASE BANK (USA),
N.A.,

Plaintiff,
CIVIL ACTION FILE
vs. NO. 10-7271-4

JILL SHERIDAN
Defendant.

RULE 5.2 CERTIFICATE

The undersigned counsel for Plaintiff, Daniel A. Greene, hereby certifies


that a true and correct copy of PLAINTIFF'S RESPONSES TO
DEFENDANT'S FIRST INTERROGATORIES and REQUEST FOR
ADMISSIONS has been served upon the Defendant by depositing the same in
the U.S. Mail affixed with sufficient postage to assure delivery, to the following
address:

JILL SHERIDAN
3266 STONEWALL DRIVE
KENNESAW, GA 30152

This l.S.- day of ----~~--I+-_+- 2010.

Daniel A. Greene, Esq.


Georgia Bar No. 105227
IN THE STATE COURT OF GWINNETT COUN1Y
STATE OF GEORGIA

MIDLAND FUNDING LLC,


ASSIGNEE OF CHASE BANK (USA),
N.A,

Plaintiff,
CIVIL ACTION FILE
vs. NO. 10-7271-4

JILL SHERIDAN
Defendant.

RULE 5.2 CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing RULE 5.2
CERTIFICATE was this day served upon the Defendant by depositing the same in
the U.S. Mail affixed with sufficient postage to assure delivery to the following
address:

JILL SHERIDAN
3266 STONEWALL DRIVE
KENNESAW, GA 30152

. This 1.5..- of_---'~~,-----/_


day

aniel A Greene, Esq.


Georgia Bar No. 105227