July 11, 2014

Headaches and Interrogatories - July 1995


From Donald Lee Wolf of Tyler (Calame, Linebarger etc.), these responses for admission presumably submitted by "someone suffering from Post 1040A Syndrome." (These answers were prepared by Al D. Thigpen of Tyler.)

Request for Admission No. One: That the following individuals are living: C.C. Martin.

Answer: Denied.

Interrogatory No. One: If the immediately preceding Request for Admission has not been admitted, state all facts known to you directly or indirectly, and which by diligence on your part and on the part of your attorneys can become or be made known, which form the basis of your denial of the immediately preceding Request for Admission or which form the basis for your inability to either admit or deny the immediately preceding Request for Admission.

Answer: Defendant objects to this interrogatory because trying to read it made defendant's attorney dizzy, disoriented, frustrated, perplexed, chagrined, confused, and feeling as if he just re-did his tax returns. Subject to this objection, defendant answers as follows: I attended his funeral.

Interrogatory No. Two: If Request for Admission No. One was denied in whole or part due to the fact that any or all of the individuals named in Request for Admission No. One are known by you to be deceased, state the date and place of death of each such deceased individual, whether such individual died with or without a will, whether such will was entered into probate, whether there is or has been any other probate action on each such individual, and as to any type of probate action, in what court and what court cause number and who are heirs or devises of each such individual.

Answer: Defendant makes the same object as above, except that defendant's attorney now has a headache. Subject to the above and this additional objection, defendant answers as follows: C.C. Martin died testate on Jan. 18, 1986...