Re: SIU Procedure / Deposition Request / Interrogatories / Request for Production
On Feb 9, 2024, at 1:56 PM, Christopher A. McElgunn <cmcelgunn@klendalaw.com> wrote:
Thank you for taking my call.
Chris
From: LuPardus vs Homesite <lupardusvshomesite@gmail.com>
Sent: Friday, February 9, 2024 12:25 PM
To: Christopher A. McElgunn <cmcelgunn@klendalaw.com>; Lonnie LuPardus <lonnielupardus@gmail.com>; lupardusvshomesite.emails@blogger.com
Subject: SIU Procedure / Deposition Request / Interrogatories / Request for Production
SIU Operations Procedure: Very well. I will include the refusal in my request to demand production. Instead of wasting time I will just send it directly to the court; you've had your chance to produce the documents.
Deposition Request: I am not available between February 15th - March 1st. Also requesting deposition be performed via Zoom. I am available February 12th (after 12:00 PM), February 13th - 14th (all day).
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Scheduling by Google Calendar |
Interrogatories:
1: See SIU Background check - Lonnie LuPardus.
2: See https://public.jococourts.org/, search Lonnie LuPardus.
3: Provided during EUO part I & II.
4: Overly broad.
Request for Production:
1. Already in possession. Calls recorded by Homesite/AFICs.
2: Already in possession. "Voicemail recordings" already in possession of Homesite/AFICs if left.
3: Already in possession. Calls recorded by Homesite/AFICs.
4: Privileged. Any recordings performed outside of Homesite/AFICs would be between myself and attorneys. K.S.A. 60-226
5: Already provided. Onedrive Shared Folder.
6: Privileged. Any documents and/or emails performed outside of Homesite/AFICs would be between myself and attorneys. K.S.A. 60-226
7: N/A
8: Already Provided. See Counterclaim submission & One Drive Shared Linked. Also Google Drive shared link).
9: Already provided. See submission to Homesite when claim was submitted.
10: Already provided. See submission to Homesite when claim was submitted.
11: Already provided. See Examination Under Oath Part I & II.
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Thanks,
______________________________
Lonnie LuPardus
LuPardus vs Homesite Insurance
P.O. Box 322 | Olathe, KS 66062
(913) 912 - 2255
Sender notified by | 02/09/24, 12:21:38 PM |
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