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Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio
IN THE WAYNE COUNTY MUNICIPAL COURT
ORRVILLE, OHIO BRANCH
JAMES CARTER 2014 CV-F-001171
PLAINTIFF COMBINED INTERROGATORIES,
REQUEST FOR ADMISSIONS &
VS PRODUCTION OF DOCUMENTS
KAYE JOHNSON
DEFENDANT
Plaintiff hereby propounds to the Defendant, (herein after “you”), the following combined
Interrogatories and Request for Admissions pursuant to Rules 33 and 36 of the Ohio Rules of
Civil Procedure, and requests that you respond within twenty eight (28) days of service of the
same.
DEFINITIONS AND INSTRUCTIONS
1. In responding, please provide all information available to you, however it was obtained,
including hearsay, and any and all information in your actual or constructive possession or
knowledge, or in the actual or constructive possession or knowledge of your attorneys,
agents, or representatives.
2. You are bound by the following duties in responding:
(a) To conduct a reasonable investigation in order to respond.
(b) To state objections in as specific manner as possible.
(c) To seasonably withdraw, amend, or supplement a response if you obtain subsequent
information which tends to indicate that the response was or became inaccurate or
incomplete.
(d) If after exercising due diligence to secure complete and full information, you are
unable to provide a complete answer, (1) to provide an answer to the extent possible:
(2), to set forth in detail the reason for your inability to complete the answer, (3) to
state whatever information or knowledge you have concerning the portion which is
unanswered; and (4) to specifically state what was done in an attempt to secure the
unknown information.
3. If you encounter any ambiguity in either a request or an instruction, so state, and set forth the
matter deemed ambiguous, and the construction chosen in responding.
4. The word document means any matter which is written, recorded, or graphic, including
originals, copies of originals, and prior drafts, whether produced, reproduced or stored in any
manner including paper, film, tapes, belts, disks, computer devices or any other information
storage system available to you.
5. A request for a document or which seeks information regarding the identification of, or
information contained in a document, may be answered by providing a copy of the
document.
6. All answers must be made separately and fully and an incomplete or evasive answer will be
deemed a failure to answer.
REQUEST FOR ADMISSION
1. Admit that you signed a rental agreement with James Carter and were knowledgeable of the
terms and conditions set forth in the agreement.Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio
Answer:
INTERROGATORY
2. If you did not admit the previous Request for Admission, please explain in detail, with
specifics, why you denied it.
Answer:
REQUEST FOR ADMISSION
3. Admit that you understood the term of the rental agreement was for one year..
Answer:
INTERROGATORY
4. Ifyou did not admit the previous Request for admission, please explain in detail, with
specifics why you denied it.
Answer:
REQUEST FOR ADMISSION
5. Admit that you also understood that there was an additional charge per month if your failed to
occupy the premises for less than one year.
Answer:
INTERROGATORY
6. If you deny the previous Requests for admission please explain in detail why you denied it.
Answer:Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio
REQUEST FOR ADMISSION
7. Admit that you also understood under the terms of the agreement that you would be
responsible for any period of vacancy should the apartment not be re rented.
Answer:
INTERROGATORY
8. If you did not admit the previous Request for Admission, please explain in detail, with
specifics, why you denied it.
Answer:
REQUEST FOR ADMISSION
9. Admit that you failed to have the utilities disconnected and finalized after vacating the unit
and further that you failed to pay the final utility bills.
Answer:
INTERROGATORY
10. If you did not admit to the previous Request for Admission, please explain in detail, with
specifics, why you denied it. Provide proof of payment of all final utility bills.
Answer:
REQUEST FOR ADMISSION
11. Admit that you understood the requirement to have the carpets professionally cleaned after
vacating and further that you failed to have the carpets professionally cleaned as required by the
rental agreement.
Answer:Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio
INTERROGATORY
12. If you do not admit to the previous Request for Admission, please explain in detail, with
specifics, why you denied it.
Answer:
REQUEST FOR ADMISSION
15. Admit that you failed to return and clean and remove all trash and debris from 1936
Highland Park Apt 6, Wooster, Ohio 44691, Ohio, after vacating the apartment.
Answer:
INTERROGATORY
16. If you do not admit to the previous Request for Admission, please explain in detail, with
specifics, why you denied it.
Answer:
REQUEST FOR ADMISSION
17. Admit that your notice specifically stated “ that Cindy’s name had come up on the Metro
waiting list and that she must have a Metro approved apartment.” .
Answer:
18. If you deny the previous Request for Admission please explain in detail, with specifics, why
you denied it.
Answer:Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio
REQUEST FOR ADMISSION
19. Admit that you were made aware by the plaintiff that the apartment in which she resided,
1936 Highland Park Apt 6, was Metro approved and that it would not be necessary for her to
relocate because of this fact...
Answer
20. If you deny the previous Request for Admission please explain in specifics why you denied
it.
REQUEST FOR ADMISSION.
21. Admit that you received a letter dated March 17, 2014, from the plaintiff that:
A. Advised you that 1936 Highland Park Apt 6, Wooster Ohio 44691 was Metro
approved.
B. That the plaintiff advised you that you would be responsible for rent until the unit was
again rented or that the term of the agreement was up
swer:
22. If you deny the previous Request for Admission, explain why you denied it.
23, Admit that you received notice from the plaintiff in less that thirty days indicating that youFiled on 10/03/2014 at 12:26 PM in Wayne County, Ohio
deposit was applied towards unpaid rent.
Answer:
24. If you deny the previous Request for Admission explain why you denied it.
25. Provide proof of payment of rent and late charges for all months that you resided at 1936
Highland Park Apt 6. Wooster Ohio 44691 from the date you took possession until the date you
vacated.
26. Provide proof of payment(s) for all utilities from the date you took possession until you
vacated 1916 Highland Park Apt 6 Wooster, Ohio 44691.
27. Provide proof of payment for having the carpets professionally cleaned upon vacating 1936
Highland Park Apt 6, Wooster Ohio 44691 as required by the rental agreement which you
signed.
28. Provide proof of payment of the cleaning charge for 1936 Highland Park Apt 6, Wooster
Ohio 44691 as stated in the rental agreement which you signed.
29. Provide proof of payment(s) of the requirement in the rental agreement when you failed to
occupy the unit at 1936 Highland Park Apt 6, Wooster, Ohio 44691 as required and stated in the
rental agreement which you signed.
mes Carter
laintiff
157 Madison Trail
Medina Ohio 44256Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio
CERTIFICATE OF SERVICE
The original and one copy of the foregoing Combined Interrogatories and Request for
Admissions was sent by regular to the defendants attorney, David Tadoro 126 North Walnut
Street, Wooster, Ohio 44691, by regular U.S. Mail C4 5, 2014.
a
VERIFICATION
I, Kaye Johnson, being first duly sworn according to law, deposes and states that I am the
Defendant, that I have read and the foregoing Requests for Admissions, Interrogatories,
Production of Documents and that the answers are true as I verily believe.
Kaye Johnson
SWORN AND SUBSCRIBED before me, a Notary Public, this day of
» 2014
Notary Public
Preview
Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio IN THE WAYNE COUNTY MUNICIPAL COURT ORRVILLE, OHIO BRANCH JAMES CARTER 2014 CV-F-001171 PLAINTIFF COMBINED INTERROGATORIES, REQUEST FOR ADMISSIONS & VS PRODUCTION OF DOCUMENTS KAYE JOHNSON DEFENDANT Plaintiff hereby propounds to the Defendant, (herein after “you”), the following combined Interrogatories and Request for Admissions pursuant to Rules 33 and 36 of the Ohio Rules of Civil Procedure, and requests that you respond within twenty eight (28) days of service of the same. DEFINITIONS AND INSTRUCTIONS 1. In responding, please provide all information available to you, however it was obtained, including hearsay, and any and all information in your actual or constructive possession or knowledge, or in the actual or constructive possession or knowledge of your attorneys, agents, or representatives. 2. You are bound by the following duties in responding: (a) To conduct a reasonable investigation in order to respond. (b) To state objections in as specific manner as possible. (c) To seasonably withdraw, amend, or supplement a response if you obtain subsequent information which tends to indicate that the response was or became inaccurate or incomplete. (d) If after exercising due diligence to secure complete and full information, you are unable to provide a complete answer, (1) to provide an answer to the extent possible: (2), to set forth in detail the reason for your inability to complete the answer, (3) to state whatever information or knowledge you have concerning the portion which is unanswered; and (4) to specifically state what was done in an attempt to secure the unknown information. 3. If you encounter any ambiguity in either a request or an instruction, so state, and set forth the matter deemed ambiguous, and the construction chosen in responding. 4. The word document means any matter which is written, recorded, or graphic, including originals, copies of originals, and prior drafts, whether produced, reproduced or stored in any manner including paper, film, tapes, belts, disks, computer devices or any other information storage system available to you. 5. A request for a document or which seeks information regarding the identification of, or information contained in a document, may be answered by providing a copy of the document. 6. All answers must be made separately and fully and an incomplete or evasive answer will be deemed a failure to answer. REQUEST FOR ADMISSION 1. Admit that you signed a rental agreement with James Carter and were knowledgeable of the terms and conditions set forth in the agreement.Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio Answer: INTERROGATORY 2. If you did not admit the previous Request for Admission, please explain in detail, with specifics, why you denied it. Answer: REQUEST FOR ADMISSION 3. Admit that you understood the term of the rental agreement was for one year.. Answer: INTERROGATORY 4. Ifyou did not admit the previous Request for admission, please explain in detail, with specifics why you denied it. Answer: REQUEST FOR ADMISSION 5. Admit that you also understood that there was an additional charge per month if your failed to occupy the premises for less than one year. Answer: INTERROGATORY 6. If you deny the previous Requests for admission please explain in detail why you denied it. Answer:Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio REQUEST FOR ADMISSION 7. Admit that you also understood under the terms of the agreement that you would be responsible for any period of vacancy should the apartment not be re rented. Answer: INTERROGATORY 8. If you did not admit the previous Request for Admission, please explain in detail, with specifics, why you denied it. Answer: REQUEST FOR ADMISSION 9. Admit that you failed to have the utilities disconnected and finalized after vacating the unit and further that you failed to pay the final utility bills. Answer: INTERROGATORY 10. If you did not admit to the previous Request for Admission, please explain in detail, with specifics, why you denied it. Provide proof of payment of all final utility bills. Answer: REQUEST FOR ADMISSION 11. Admit that you understood the requirement to have the carpets professionally cleaned after vacating and further that you failed to have the carpets professionally cleaned as required by the rental agreement. Answer:Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio INTERROGATORY 12. If you do not admit to the previous Request for Admission, please explain in detail, with specifics, why you denied it. Answer: REQUEST FOR ADMISSION 15. Admit that you failed to return and clean and remove all trash and debris from 1936 Highland Park Apt 6, Wooster, Ohio 44691, Ohio, after vacating the apartment. Answer: INTERROGATORY 16. If you do not admit to the previous Request for Admission, please explain in detail, with specifics, why you denied it. Answer: REQUEST FOR ADMISSION 17. Admit that your notice specifically stated “ that Cindy’s name had come up on the Metro waiting list and that she must have a Metro approved apartment.” . Answer: 18. If you deny the previous Request for Admission please explain in detail, with specifics, why you denied it. Answer:Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio REQUEST FOR ADMISSION 19. Admit that you were made aware by the plaintiff that the apartment in which she resided, 1936 Highland Park Apt 6, was Metro approved and that it would not be necessary for her to relocate because of this fact... Answer 20. If you deny the previous Request for Admission please explain in specifics why you denied it. REQUEST FOR ADMISSION. 21. Admit that you received a letter dated March 17, 2014, from the plaintiff that: A. Advised you that 1936 Highland Park Apt 6, Wooster Ohio 44691 was Metro approved. B. That the plaintiff advised you that you would be responsible for rent until the unit was again rented or that the term of the agreement was up swer: 22. If you deny the previous Request for Admission, explain why you denied it. 23, Admit that you received notice from the plaintiff in less that thirty days indicating that youFiled on 10/03/2014 at 12:26 PM in Wayne County, Ohio deposit was applied towards unpaid rent. Answer: 24. If you deny the previous Request for Admission explain why you denied it. 25. Provide proof of payment of rent and late charges for all months that you resided at 1936 Highland Park Apt 6. Wooster Ohio 44691 from the date you took possession until the date you vacated. 26. Provide proof of payment(s) for all utilities from the date you took possession until you vacated 1916 Highland Park Apt 6 Wooster, Ohio 44691. 27. Provide proof of payment for having the carpets professionally cleaned upon vacating 1936 Highland Park Apt 6, Wooster Ohio 44691 as required by the rental agreement which you signed. 28. Provide proof of payment of the cleaning charge for 1936 Highland Park Apt 6, Wooster Ohio 44691 as stated in the rental agreement which you signed. 29. Provide proof of payment(s) of the requirement in the rental agreement when you failed to occupy the unit at 1936 Highland Park Apt 6, Wooster, Ohio 44691 as required and stated in the rental agreement which you signed. mes Carter laintiff 157 Madison Trail Medina Ohio 44256Filed on 10/03/2014 at 12:26 PM in Wayne County, Ohio CERTIFICATE OF SERVICE The original and one copy of the foregoing Combined Interrogatories and Request for Admissions was sent by regular to the defendants attorney, David Tadoro 126 North Walnut Street, Wooster, Ohio 44691, by regular U.S. Mail C4 5, 2014. a VERIFICATION I, Kaye Johnson, being first duly sworn according to law, deposes and states that I am the Defendant, that I have read and the foregoing Requests for Admissions, Interrogatories, Production of Documents and that the answers are true as I verily believe. Kaye Johnson SWORN AND SUBSCRIBED before me, a Notary Public, this day of » 2014 Notary Public