V I R G I N I A: IN THE CIRCUIT COURT OF ALEXANDRIA CITY ERIC J. BONETTI Plaintiff, v. Lindsey M. Anders Defendant.
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CL NO. 20001941
PLAINTIFF’S FIRST INTERROGATORIES TO DEFENDANT COMES NOW Plaintiff, ERIC J. BONETTI, in the above-titled action and, pursuant to Rule 4:0 et seq. of the Rules of the Supreme Court of Virginia, hereby requests that Defendant, Lindsey M. Ander, answer fully, in writing, and under oath the following interrogatories in accordance with the Virginia Rules pertaining to discovery. INSTRUCTIONS A.
Answer each Interrogatory separately and fully in writing and under oath, unless
it is objected to, in which case the reasons for objections must be stated. You are requested to serve a copy of your answers upon plaintiff within twenty-one (21) days at 4129 Fountainside Lane #203, Fairfax VA 22030. B.
These Interrogatories are continuing in nature and require you to update and/or
correct the information given pursuant to Rule 4:1(E). C.
Produce all documents that were used in preparation of your answers to
Interrogatories or that are relevant to the matters addressed by the Interrogatories or your answers.
D.
If any document to which you refer in your answers to these Interrogatories will
be withheld because of claimed privilege or work-product rule, the identity and fact of existence of such document, and specifically why you claim it should be exempt from your production, including the nature of the privilege being claimed, must still be set forth. Unless divulging such information would cause disclosure of the allegedly privileged information, the following information should be provided in the objection, if known or reasonable available. a.
For oral communications, the name of the person making the
communication and the names of the persons present while the communication was made, and, where not apparent, the relationship of the persons present to the person making the communication; the date and place of the communication; and the general subject matter of the communication. b.
For documents, the type of document; the general subject matter of the
document; the date of the document; and such other information as is sufficient to identify the document, including, where appropriate, the author, addressee, custodian, and any other recipients of the document, and were not apparent, the relationship of the author, addressee, custodian, and any other recipient to each other. E.
These instructions and definitions should be construed to require answers based
upon the knowledge of any information available to you, as well as your agents, representatives, and, unless privileged, attorneys. Any requested information, unless privileged, which is known by any of your attorneys, accountants, or other agents, acquired while acting on your behalf, shall be given in response to these Interrogatories. Bonetti v. Anders Interrogatories to Defendant Page 2 of 11
F.
No part of an interrogatory should be left unanswered merely because an
objection is interposed to another part of the interrogatory. If a partial or incomplete answer is provided, you shall state that the answer is partial or incomplete. If, in answering these Interrogatories, you encounter any ambiguity when construing a question, instruction, or definition, your answer shall set forth the matter deemed in the construction used in answering. To the extent you do not know the precise information requested, provide your best estimate thereof. DEFINITIONS A.
The term “date” means the exact day, month, and year, if ascertainable, or, if
not, your best approximation thereof. B.
The word “person,” used in these Interrogatories, includes both the singular and
plural, and includes legal, business, or governmental entities and organizations as well as individual, natural persons. C.
Where the name or identity of a person is requested, state full name, home
address, telephone number, and also business address and telephone number, if known. When referring to a person, to “identify” means to state the person’s full name, present or last known address, relationship to you, and, when referring to a natural person, additionally, the present or last known place of employment. If the business and home telephone numbers are known, and if the person is not a party or present employee of a party, said telephone numbers shall be provided. Once a person has been identified in accordance with this subparagraph, only the name of the person need be listed in response to subsequent discovery requesting the Bonetti v. Anders Interrogatories to Defendant Page 3 of 11
identification of that person. D.
Where referring to documents, to “identify” means to state the: (i) type of
document; (ii) general subject matter; (iii) date of the document; (iv) the author(s), addressee(s), and recipient(s); and (v) its present or last known location and custodian, or, alternatively, to produce the document. If pursuant to Rule 4:8(f) you elect to specify and produce records in answer to any Interrogatory, the specification shall be in sufficient detail to permit us to locate and identify the records from which the answer may be ascertained. E.
The term “communication” means the transmittal of information by any means.
F.
When referring to communications, to “identify” means to state the: (i)
description of the subject matter communicated; (ii) the date it took place; (iii) the means of communication; (iv) the place when it occurred; (v) who initiated the communication; and (vi) the identity of each person who sent, received, participated in, or has knowledge of it. G.
The term “document” and “documents” are defined to be synonymous in
meaning and equal in scope to the usage of the term “documents” in Rule 4:9(a) and include(s) the term “writing”. Electronic mail is included within the definition of the term “document”. A draft or non-identical copy is a separate document within the meaning of the term “document”. H.
The term “concerning” means relating to, referring to, describing, evidencing, or
constituting. I.
The terms “you” or “your” include the person(s) to whom these Interrogatories
are addressed, and all of that person’s agents, representatives, and attorneys. J.
The term “Plaintiff” refers to ERIC BONETTI.
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K.
The terms “and” and “or” shall be both conjunctive and disjunctive.
L.
Where appropriate, the masculine gender may be considered to be substituted
for the feminine gender, and vice versa, and the singular may be considered substituted for the plural and vice versa. M.
Unless otherwise indicated, these Interrogatories refer to the time, place, and
circumstances of the subject matter mentioned or complained of in the pleadings. INTERROGATORIES 1.
List and explain in detail all conversations, correspondence, social media posts,
emails, text messages, and other communications, from January 27, 2019 to the present, in which you state, accuse, or imply that Plaintiff has engaged in illegal conduct, should face criminal prosecution, or be sentenced to jail. ANSWER:
2.
List all pseudonyms, handles, or assumed names under which you have made
comments about Plaintiff that state, accuse, or imply that Plaintiff has engaged in illegal conduct, should face criminal prosecution, or be sentenced to jail. ANSWER:
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3.
List and explain all times in which you have made social media posts or other
publications and in doing so impersonated the Plaintiff. Provide details of these posts and publications. ANSWER:
4.
List and explain in detail all communications in which any clergy, current or
former member, or person associated with Grace Episcopal Church has told you, or you have discussed with them, allegations that Plaintiff has engaged in illegal activity including, but not limited to, allegations that Plaintiff has made terroristic threats, embezzled, should face criminal charges, or has otherwise behaved in an illegal manner. ANSWER:
5.
List and explain in detail all communications you have had in which clergy or
members affiliated with Grace Episcopal Church in Alexandria VA, friends or family have admitted or acknowledged that Robert H. Malm provided false information in conjunction with his allegations that Plaintiff threatened persons associated with the church. ANSWER:
6.
Explain in detail any communications you have had with representatives of the
Alexandria police department concerning allegations that Plaintiff threatened members of Grace Episcopal Church in Alexandria Virginia. Include the dates, persons with whom you spoke, Bonetti v. Anders Interrogatories to Defendant Page 6 of 11
and the phone numbers or email addresses you used. ANSWER:
7.
List and explain any statements or communications you have made concerning
the Plaintiff, from January 27, 2019 to the present, that you knew to be false when you made them, or later learned to be false. ANSWER:
8.
List and explain all communication you have had with any other person in which
you agreed to collaborate, work together, cooperate, or share information in order to prevent Plaintiff from criticizing Grace Episcopal Church, its clergy, its members, or any person connected or affiliated with the church. ANSWER:
9.
Explain in detail all conversations you have had with any clergy associated with
Grace Episcopal Church Alexandria in which the clergyperson, directly or by implication, indicated that he or she has made false statements about the Plaintiff. ANSWER:
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10.
Explain in detail all communications you have had with Lisa Gardner in which you
allege that Plaintiff has engaged in illegal activities, or assert that Plaintiff should be arrested or jailed.
ANSWER:
11.
Explain in detail how you learned about Plaintiff’s alleged blogging connected
with Grace Episcopal Church Alexandria, your response, and the names and contact information of all persons who can corroborate your response. ANSWER:
12.
Provide all phone numbers, email addresses, and social media account
identifiers by which you have made allegations or implications that the Plaintiff engaged in illegal behavior, or asserted that Plaintiff should be arrested or jailed. ANSWER:
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13. Have you made any statements to any person connected with this proceeding that is knowingly or unknowingly untruthful? If so, explain in detail. ANSWER:
Respectfully submitted, ERIC BONETTI Pro Se Plaintiff 4129 Fountainside Lane 203 Fairfax VA 22030 Eric.bonetti@me.com
CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing First Interrogatories to Defendant was emailed and mailed, via USPS First Class mail, to Counsel for Defendant on September 30, 2020 per 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 Diane DiBlasio, Esq. Niles, Barton & Wilmer, LLP 111 South Calvert Street Suite 1400 Baltimore, MD 21202 Telephone: 410-783-6300 Email: dediblasio@nilesbarton.com Counsel for Grace Episcopal Church Bonetti v. Anders Interrogatories to Defendant Page 9 of 11
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ATTEST: COMMONWEATH/STATE OF _______________ COUNTY OF _______________________ I, ________________________, a Notary Public in and for the County and Commonwealth/State aforesaid, whose commission expires on the ___ day of _____________, 20___, do hereby certify that _______________________, whose name(s) is/are signed to the foregoing writing bearing date of the ___ day of ___________, 20___, has acknowledged the same before me in the County and Commonwealth/State aforesaid. GIVEN UNDER MY HAND THIS ___ day of _______________, 20___. ________________________ NOTARY PUBLIC My commission expires: ____________________________ Notary Registration Number: ________________________ NOTARIAL SEAL REQUIRED.
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