Requests for Production Served on Episcopal Diocese of Virginia

April 18, 2021

Clerk of Court Federal District Court, Eastern District of Virginia Albert V. Bryan U.S. Courthouse 401 Courthouse Square Alexandria, VA 22314

BONETTI v. MALM et al

Dear Madam/Sir:

Please find enclosed several discovery requests I have served upon defendants. While I recognize that these requests may be premature, as the parties have not yet held the requisite Rule 26(f) conference, I believe that it makes sense to send these now, and to provide copies to the court, in light of the defendants’ past litigation-related conduct, including perjury, concealment of evidence, and witness tampering. Thus, I believe there is a better chance of maintaining a level playing field in litigation.

I also want to alert the court, and opposing counsel by copy of this letter, that I anticipate we may have certain items for which a motion to seal, or a motion for an HSD pursuant to the Court’s Standing Order of April 15, 2021, will be requested. Should this become necessary, it is my intent to motion the court at the appropriate time.

Thank you.

Eric J. Bonetti Pro Se Plaintiff 4129 Fountainside Lane 203 Fairfax VA 22030 Eric.bonetti@protonmail.com 703-973.4984