Motion for Supplemented Discovery Responses

V I R G I N I A:

IN THE CIRCUIT COURT OF ALEXANDRIA CITY

ERIC J. BONETTI

Plaintiff,

v.

ROBERT H. MALM

Defendant

: : : : : CL NO. 2000 2631 : : :

Motion Under Va. R. Sup. Ct. 4:1 For Supplemental Responses to Discovery

COMES NOW Plaintiff, Eric J. Bonetti in the above matter and asks the Court to order Defendant Malm to supplement his discovery responses in light of evidence shared with defense counsel that Defendant knowingly made false statements in related prior litigation before this court. A copy of three of Defendant’s false statements is attached.

A request to voluntarily update discovery has been made to defense counsel and this motion will be withdrawn should defendant comply.

Respectfully submitted,

Eric J. Bonetti

Pro se plaintiff

4129 Fountainside Lane 203

Fairfax VA 22030

703-973-4984

Eric.bonetti@protonmail.com

Certifications

Movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without court action.

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was emailed to Counsel for Defendant on February 17, 2020 to the following:

Wayne Cyron, Esq.

100 North Pitt Street, Suite 200 Alexandria, Virginia 22314 Telephone: 703-299-0600 E-mail: cml@cyronmiller.com Counsel for Robert H. Malm

Matthew Youssef, Esq. Niles, Barton & Wilmer, LLP 111 South Calvert StreetSuite 1400 Baltimore, MD 21202 Telephone: 410-783-6300 Email: mjyoussef@nilesbarton.com Counsel for Grace Episcopal Church

Sworn testimony re Sigrid Yahner, my late mother Sworn response, initial interrogatories:

Sworn response, recent interrogatories:

Sworn Testimony, Wareham District Court:

V I R G I N I A:

IN THE CIRCUIT COURT OF ALEXANDRIA CITY

ERIC J. BONETTI

Plaintiff,

v.

ROBERT H. MALM

Defendant

: : : : : CL NO. 2000 2631 : : :

ORDER OF COURT

AND NOW, this ______ day of March, 2021, the Court orders Defendant to update his discovery responses in light of evidence that he has proferred false and inaccurate information in his interrogatories and other discovery responses.

BY THE COURT,

Judge

IN THE CIRCUIT COURT FOR THE CITY OF ALEXANDRIA ERIC J. BONETTI,

Plaintiff,

vs.

CIVIL ACTION NUMBER: 2020 06480

ROBERT H. MALM,

Defendant

PRAECIPE

The Clerk is requested to place the captioned matter on the docket for 10:00 a.m. on March 25,

so that Plaintiff’s Motion for Supplemental Discovery Responses may be heard for argument.

The matter will be heard remotely via Microsoft Teams. Opposing counsel/party will receive an

email from the Court two (2) days prior to the Motions Day hearing. The Court’s email will include a link to the Microsoft Teams meeting and a telephone number to be used by those participants who do not have internet access.

Respectfully submitted,

Eric J. Bonetti Pro se plaintiff 4129 Fountainside Lane 203 Fairfax VA 22030 703-973-4984 Eric.bonetti@protonmail.com