Howdy All,
To get it into this thread with the other text/info from
the Civil Suit.
Other posts in this thread containing text from the civil suit:
Are [ame="http://www.websleuths.com/forums/showpost.php?p=3893995&postcount=797"]here (797)[/ame], [ame="http://www.websleuths.com/forums/showpost.php?p=3895639&postcount=802"]here (802)[/ame] and [ame="http://www.websleuths.com/forums/showpost.php?p=3895645&postcount=803"]here (803)[/ame].
From the Request for Production (to JMM)
p. 5 of 40
Pursuant to the provisions of Illinois Supreme Court Rule 214, you are hereby requested to furnish Plaintiffs' counsel with copies of the following:
1. Copies of Christopher Coleman's complete personnel file.
2. Copies of all policies of Joyce Meyer Ministries regarding employment with the organization.
3. Copies of Christopher Coleman's work schedule for the past 36 months, including all out of town events, appointments, destinations, and schedules.
4. Copies of all airplane schedules, both commercial and private on which Christopher Coleman is listed as a passenger.
5. Copies of all airplane manifests, both commercial and private on which Christopher Coleman is listed as a passenger.
6. Copies of all private airplane manifests, held by Joyce Meyer Ministries, Inc. which list all passengers.
7. Copies of all reports, correspondence, contracts, agreements or other writings regarding the facts and circumstances alleged in Plaintiffs' Complaint.
8. Copies of the Joyce Meyer Ministries, Inc. policy of employment as it related to Christopher Coleman.
9. Copies of all correspondence, notes, memorandums, deeds, contracts, policies or other documents relating to the hiring of Christopher Coleman.
From the Interrogatories to Respondent in Discovery (JMM)
p. 7-9 of 40
Pursuant to Supreme Court Rule, you are requested to answer the following Interrogatories under oath within twenty-oight (28) days of service hereof;
1. State the full name, current residence, and business address, and relationship to Joyce Meyer Ministries, Inc. of all persons answering and signing these interrogatories.
2. Have you or anyone acting on your behalf had any conversations with any person at any time with regard to the manner in which the occurrence complained of in Plaintiffs' Complaint occurred? If your answer to this interrogatory is in the affirmative, state the following:
(a) The date(s) of such conversations and/or statements;
(b) The place of such conversations and/or statements;
(c) All persons present for the conversations and/or statements;
(d) The matters and things stated by the person in the conversation and/or statements;
(e) Whether the conversation was oral, written, and/or recorded; and
(f) Who has possession of the statement if written and/or recorded?
3. Have you overheard any conversations made by any person at any time with regard to the occurrence complained of in Plaintiffs' Complaint? If your answer to this interrogatory is in the affirmative, state the following:
(a) The date(s) one overheard such conversations and/or statements;
(b) The place one overheard such conversations and/or statements;
(c) All persons present for the conversations and/or statements;
(d) The matters and things overheard by the person in the conversation and/or statements;
(e) Whether the conversation was oral, reduced to writing, and/or recorded; and
4. Do you know of any statements otherwise taken by any former or current employee or staff member of Respondent in Discovery with regard to the allegations made in Plaintiffs' Complaint? and, if so, state the following:
(a.) Identify who gave such statement and the date the statement was given;
(b.) Identify the format of the statement, oral, written, videotaped, audio taped, or otherwise;
(c.) Identify who has current possession of said statement;
(d.) For each such statement taken, identify the persons present at the time of statement, and the person requesting the taking of each statement.
5. List the names and addresses of all other persons (other than yourself and persons heretofore listed) who have knowledge of the facts of the occurrence and damages claimed to have resulted from the actions set forth in Plaintiffs' Complaint.
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Some blurbs from the complaint:
p. 36 of 40 Complaint Count I
6. As a direct and proximate result of the Defendant's conduct which caused the deaths of Plaintiffs' decedents, the Plaintiffs'decedents died and their next of kin have been permanently deprived of their love, companionship, society, support, guidance, and have incurred and become liable for large sums of money in burial expenses, all to their damage in a substantial amount.
p. 37 of 40 Complaint Count II
5. At all times herein mentioned, Defendant, Christopher Coleman is guilty of causing the deaths of the Plaintiffs' decedents by one or more of the following negligent acts or omissions:
a.) Negligently and carelessly failing to provide plaintiffs'decedents a safe place to live.
b.) Negligently and carelessly failing to protect plaintiffs'decedents from a dangerous condition when Defendant knew or should have known of the dangerous condition.
c.) Negligently and carelessly failing to protect plaintiffs'decedents from an unreasonable risk of harm which Plaintiffs' decedents would neither discover nor appreciate and thus would be unable to seek protection.
6. As a direct and proximate result of the aforesaid negligent acts, omissions and carelessness of the Defendant as aforesaid, Plaintiffs' decedents died and their next of kin have been permanently deprived of their love, companionship, society, support, guidance, and have incurred and become liable for large sums of money in burial expenses, all to their damage in a substantial amount.
