UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA ERIC J. BONETTI, Plaintiff, CIVIL Case No.:
vs. EPISCOPAL DIOCESE OF VIRGINIA, ROBERT HILLER MALM, CITY OF ALEXANDRIA, COMMONWEALTH OF VIRGINIA Defendants
AMENDED REQUEST FOR PRODUCTION OF DOCUMENTS COMES NOW Plaintiff, Eric J. Bonetti, and files this request for production of documents pursuant to the Federal Rules of Civil Procedure to Defendant Robert H. Malm. 1. In your responses to Plaintiff’s request for an injunction, you state that a two-year protective order was entered based on harassment and threats against Defendant Malm and his family Please provide a copy of the legislation or a citation to the relevant legislation in which a protective order is authorized based on allegations of harassment. 2. In conjunction with Request Number 1, please provide copies or documentation of all threats that you allege Plaintiff has made against Defendant Malm and his family. In doing so, indicate the source, and author, the date of publication, and the exact words that constituted a threat of imminent harm pursuant to the Virginia protective order statute. Because Defendant Malm withheld at least 16 documents directly within the purview of discovery in the initial litigation, including two facially detrimental to Malm’s claims that he had been threatened, you are requested not to refer to documents previously supplied, but instead to supply all relevant, nonprivileged documents in your possession or control. If any are withheld due to privilege, identify the document, its non-privileged content, and the reason you assert it is privileged. If
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