WMSCOG First Objections & Responses to Newton’s Interrogatories – WMSCOG vs. Colon, Newton VA #2011-17163

VIRGINIA:

IN THE CIRCUIT COURT OF FAIRFAX COUNTY

_______________________________________________________
WORLD MISSION SOCIETY CHURCH
OF GOD, A NEW JERSEY NON-PROFIT
CORPORATION,
Plaintiff, Case No.: 2011-17163
v.
MICHELE COLON and
TYLER J. NEWTON
Defendants.
_______________________________________________________

PLAINTIFF’S FIRST OBJECTIONS AND RESPONSES TO DEFENDANT TYLER NEWTON’S FIRST SET OF INTERROGATORIES

Plaintiff World Mission Society Church of God, a New Jersey Non-Profit Corporation (“WMSCOG”), by counsel, responds to Defendant Tyler Newton’s (“Newton”) First Set of Interrogatories as follows:

GENERAL OBJECTIONS

Plaintiff asserts and expressly incorporates by reference the following General Objections to each of its responses. By providing a specific response to any Interrogatory or Request for Production, Plaintiff does not waive or otherwise limit these General Objections. Furthermore, reference to these General Objections in any specific response shall not waive or otherwise limit the applicability of these General Objections to each and every other response.
Plaintiff objects to each Interrogatory and Request for Production to the extent that it calls for information or documents protected by the attorney-client privilege or any other privilege. Such information or documents will not be disclosed or produced. Where the applicability of this General Objection is readily apparent on its face from the text of the Interrogatory or Request for Production, Plaintiff may also make a specific objection (hereinafter, an objection on the ground of “Privilege”) pursuant to this paragraph, although the failure to make such a specific objection shall not he deemed to be a waiver of this General Objection.
Plaintiff objects to each Interrogatory and Request for Production to the extent that it seeks information or documents prepared by Plaintiff or its representatives in anticipation of litigation or for trial. Such information or materials will not be disclosed or produced. Where the applicability of this General Objection is readily apparent on its face from the text of the lnterrogatory or Request for Production, Plaintiff may also make a specific objection (hereinafter, an objection on the ground of “Work Product”) pursuant to this paragraph, although the failure to make such a specific objection shall not be deemed to he a waiver of this General Objection.
Plaintiff objects to each lnterrogatory and Request for Production to the extent that it seeks information or documents not relevant and not reasonably calculated to lead to the discovery of admissible evidence with respect to the claims or defenses of any party to this litigation. Where the applicability of this General Objection is readily apparent on its face from the text of the Interrogatory or Request for Production, Plaintiff may also make a specific objection (hereinafter, an objection on the ground of “Relevance”) pursuant to this paragraph, although the failure to make such a specific objection shall not be deemed to be a waiver of this General Objection.
Plaintiff objects to each Interrogatory and Request for Production to the extent that it seeks information or documents that are vexatious or unduly burdensome to obtain. Where the applicability of this General Objection is readily apparent on its face from the text of the lnterrogatory or Request for Production, Plaintiff may also make a specific objection (hereinafter, an objection on the ground of “Undue Burden”) pursuant to this paragraph, although the failure to make such a specific objection shall not be deemed to be a Waiver of this General Objection.
Plaintiff objects to each Interrogatory and Request for Production to the extent that it is ambiguous, vague, or otherwise incomprehensible. Where the applicability of this General Objection is readily apparent on its face from the text of the Interrogatory or Request for Production, Plaintiff may also make a specific objection (hereinafter, an objection on the ground of “Vagueness”) pursuant to this paragraph, although the failure to make such a specific objection Shall not be deemed to be a waiver of this General Objection.
Plaintiff objects to each lnterrogatory and Request for Production to the extent that it is overbroad and fails to set forth with reasonable particularity the information requested. Where the applicability of this General Objection is readily apparent on its face from the text of
the lnterrogatory or Request for Production, Plaintiff may also make a specific objection (hereinafter, an objection on the ground of “Overbreadth”) pursuant to this paragraph, although the failure to make such a specific objection shall not be deemed to be a waiver of this General Objection.
Plaintiff objects to each Interrogatory and Request for Production to the extent that it seeks private, confidential, trade secret, or proprietary information or documents of Plaintiff or third-parties. Defendant has specifically expressed intent to disseminate information provided through discovery to the public, which will harm both Plaintiff and any third parties identified through discovery. Plaintiff will divulge such information or documents only pursuant to the terms of an appropriate Protective Order to be agreed to by the parties. Where the applicability of this General Objection is readily apparent on its face from the text of the Interrogatory or Request for Production, Plaintiff may also make a specific objection (hereinafter, an objection on the ground of “Proprietary Information”) pursuant to this paragraph, although the failure to make such a specific objection shall not he deemed to be a waiver of this General Objection.
Plaintiff objects to each Interrogatory and Request for Production to the extent that it seeks information that is already in the possession, custody, or control of defendants or any of the defendants and/or counsel for same, or to the extent that it seeks information that is available to defendants from other sources with equivalent ease and expense.
Plaintiff objects to each Interrogatory and Request for Production as overly broad and unduly burdensome to the extent that it is unlimited in time. Plaintiff will interpret the Requests as restricted to information or materials created or obtained in or around the time periods relevant to the alleged acts and omissions reasonably related to the claims and defenses in the action.
An objection in response to any Interrogatory or Request for Production does not indicate the existence of any information or documents responsive to such Interrogatory or Request for Production.
Plaintiffs responses below are subject to all objections as to competence, relevance, materiality, admissibility, and all other objections that would require the exclusion of any statement contained herein if such statement were made by a witness present and testifying in court. All such objections and grounds are reserved and may be interposed at any motion, hearing, or the time of trial.
Plaintiff objects to any request which requires it to answer, supplement answers, take any other action, or refrain from taking any action, not specifically required of it under the Rules of the Virginia Supreme Court.
Plaintiff has not yet completed its investigation and discovery or its preparation for trial. All responses are based only upon such information and documents as are presently available and specifically known to Plaintiff at this time. Further discovery, independent
investigation, legal research, expert consultation and analysis may supply additional facts, and establish entirely new factual conclusions and legal contentions all of which may lead to substantial additions to, changes in, and variations from the responses set forth below. The
following responses are given without prejudice to Plaintiffs right to produce evidence of additional information. Accordingly, Plaintiff reserves the right to change any and all responses given below. The responses below are made in a good faith effort to supply as much information as is presently known in accordance with the Rules of the Virginia Supreme Court, but should in no way be used to the prejudice of Plaintiff in relation to further discovery, research or analyses.
Plaintiff is the “World Mission Society, Church of God a NJ Nonprofit Corporation,” an independent member of a larger organization, and therefore does not have information regarding other unrelated independent members of that larger organization, or information regarding that parent organization.

INTERROGATORIES

INTERROGATORY NO. 1

Identify each person whom you believe may have personal or hearsay knowledge of facts relating to the allegations contained in the Complaint and/or the Answer thereto and describe generally the-knowledge you impute to each person so identified.

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order. Plaintiff further objects to this Interrogatory on the grounds of Privilege, Work Product, Overbreadth, and Undue Burden to the extent that it seeks anyone and anyone who may have any knowledge of this matter whatsoever, which may include hundreds of people unknown to Plaintiff as a result of Defendant’s website.

RESPONSE:

Subject to and without waiving its objections, Plaintiff identifies: Tyler Newton and Michele Colon, see the Complaint and Answer. Plaintiff reserves the right to supplement its response.

INTERROGATORY NO. 2

Identify all known meetings, conversations, and correspondence between WMSCOG and Colon. Include in your answer an identification of who participated and what was said and discussed during such communications.

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order. Plaintiff further obj ects to this Interrogatory on the grounds of Overbreadth, and Undue Burden to the extent that it seeks information otherwise available to Defendant and to the extent that Colon was a member of WMSCOG, and therefore it is impossible to identify every responsive communication.

RESPONSE:

Subject to and without waiving its objections, Plaintiff identifies: See communications identified in the Complaint.

INTERROGATORY NO. 3

Identify each and every individual who was previously a member of WMSCOG but has left (for any reason) WMSCOG since 2009. For each individual, identify the date that individual became a member, the date they left WMSCOG and any agreements entered into between WMSCOG and each individual (whether a non-disclosure agreement or other agreement).

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order. Furthermore this lnterrogatory seeks the private information of uninvolved, unrelated third parties, and therefore seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Plaintiff further objects to this Interrogatory on the grounds of Overbreadth and Undue Burden.

RESPONSE:

Subject to and without waiving its objections, Plaintiff identifies: Michele Colon. Plaintiff reserves the right to supplement its response.

INTERROGATORY N0. 4

Describe, in detail, any and all business relationships, donative relationship or other relationship between WMSCOG and Big Shine Worldwide, Inc.

OBJECTION:

INTERROGATORY NO. 5

Identify each and every “branch” of the WMSCOG (including New Jersey), as described in paragraph 12 of the Complaint located within the United States. For each branch, provide the location, corporate formation information, number of members, annual budget and identify all senior leadership (pastors, missionaries, deacons/deaconesses, and any other senior leadership), and identify both the Korean and English names used by each such individual.

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds and to the extent that it seeks information that is not within the possession, custody, or control of Plaintiff. Plaintiff is the “World Mission Society, Church of God a NJ Nonprofit Corporation,” an independent member of a larger organization, and therefore does not have information for each “branch” “located within the United States” as requested by Defendant. Plaintiff further objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order. Plaintiff further objects to this Interrogatory on the grounds of Overbreadth and Undue Burden, as this Interrogatory seeks the private information of uninvolved, unrelated third parties, and therefore seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Plaintiff further objects on the grounds that the term “senior leadership” is vague.

RESPONSE:

Subject to and without waiving its objections, Plaintiff identifies:

World Mission Society Church of God a NJ Nonprofit Corporation
Address: 305 Godwin Ave. Ridgewood, NJ 07450
Corporate Formation Information: EIN26-3675159, NJ Business ID- 0400232791
Number of Members: 456

Branch Churches

World Mission Society Church of God a NJ Nonprofit Corporation 2nd Branch Address: 160 Palisades Ave. Bogota, NJ 07603 Corporate Formation Information: EIN26-3675159, NJ Business ID- 0400232791 Number of Members: 180
World Mission Society Church of God Address: 160 Palisades Ave. Bogota, NJ 07603 Corporate Formation Information: EIN~263675159, NJ Business ID- 0400232791 Number of Members: 180
World Mission Society Church of God Address: 85 Winthrop Tr. Meriden, CT 06451 Corporate Formation Information: CT Business ID0830507 Number of Members: 180
World Mission Society Church of God Address: 7741 Baltimore Annapolis Blvd. Glen Burnie, MD 21060 Corporate Formation Information: MD Business Number of Members: l60
World Mission Society Church of God Address: 700 A ? St. NE. Washington, DC 20002 Corporate Formation Information: DC Business IDN0000001627 Number of Members: 65
World Mission Society Church of God Address: 875 Fox Chase Rd. Jenkintown, PA 19046 Corporate Formation Information: PA Business ID – 4093343 Number of Members: 60
World Mission Society Church of God Address: 128 South River Rd. Bedford, NH 03110 Corporate Formation Information: None Number of Members: 51
World Mission Society Church of God Address: 15 W 39th st. 5th Floor, NY, NY 10018 Corporate Formation Information: NY Business ID 006806 Number of Members: 120
World Mission Society Church of God Address: 125 Cedar St. New York, NY 10007 Corporate Formation Information: NY Business ID – 006806 Number of Members: 45
World Mission Society Church of God Address: 70-02 Cypress Hills St. Ridgewood, NY 11385 Corporate Formation Information: NY Business ID – 006806 Number of Members: 120
World Mission Society Church of God Address: 43 Moonachie Rd. Hackensack, NJ Corporate Formation Information: EIN-26-3675159, NJ Business ID- 0400232791 Number of Members: 74
World Mission Society Church of God Address: 1440 Howe Ln. North Brunswick, NJ 08902 Corporate Formation Information: EIN26-3675159, NJ Business ID- 0400232791 Number of Members: 83
World Mission Society Church of God Address: 5252 Lyngate Ct. Suite 100. Burke, VA 22015 Corporate Formation Information: VA Business ID-F188392-7 Number of Members: 130
World Mission Society Church of God Address: 4646 Old Princess Anne Rd. Virginia Beach, VA Corporate Formation Information: VA Business Number of Members: 43
World Mission Society Church of God Address: 115 River Rd. Edgewater, NJ Suite 103 Corporate Formation Information: NJ Business ID- 0400232791 Number of Members: 15

Church members also meet in the following cities, though they meet in the homes of a member and do not necessarily have a set meeting place or hierarchy.

Boston
Long Island, NY
Delaware
Pittsburgh
Kentucky
Delaware
Richmond, VA
Puerto Rico
Buffalo
Wilmington, NC

Plaintiff reserves the right to supplement its response.

INTERROGATORY N0. 6

Describe, in detail, the relationship between the New Jersey Branch of WMSCOG and the main headquarters and/or central location of WMSCOG in South Korea as described in paragraph 61 of the Complaint, including any financial payments or transfers to/from between the branches and the South Korean location’s role in doctrine and theology of the New Jersey Branch of WMSCOG.

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds and to the extent that it seeks information that is not within the possession, custody, or control of Plaintiff. Plaintiff is the “World Mission Society, Church of God a NJ Nonprofit Corporation,” an independent member of a larger organization, and therefore does not have information for each “branch” “located within the United States” as requested by Defendant. Plaintiff further objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal
information that will be supplied only after entry of an appropriate Protective Order. Plaintiff further objects to this Interrogatory on the grounds of Overbreadth and Undue Burden, as this Interrogatory seeks the private information of uninvolved, unrelated third parties, and therefore
seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

RESPONSE:

Subject to and without waiving its objections, Plaintiff states: The NJ WMSCOG contacts the headquarters in South Korea for reasons including, but not limited to, Spiritual Guidance, overall direction in Church matters, and financial support.

The headquarters in South Korea provides Financial Support for such things as mortgages, rent payments, construction, certain item purchases, etc.

Tithes and Certain Special offerings are given to the head office in Korea via a bank account in the Woori bank located here in the United States. From these Tithes and Special offerings the Headquarters support the branch churches in the East Coast.

INTERROGATORY NO. 7

For each senior leader as identified in Interrogatory No. 5 above, identify any contracts, business ownership interests or employment of those individuals outside WMSCOG. For each contract, ownership interest or position, identify the compensation received by the senior leader, the name and nature of the business, and describe any and all other relationship of the business to WMSCOG.

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that Will be supplied only after entry of an appropriate Protective Order. Plaintiff further objects to this Interrogatory on the grounds of Overbreadth and Undue Burden, as this Interrogatory seeks the private information of uninvolved, unrelated third parties, and therefore seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Plaintiff further objects on the grounds that the term “senior leader” is vague.

RESPONSE:

See response to Interrogatory #5. Plaintiff reserves the right to supplement its response.

INTERROGATORY NO. 8

Identify any current or former member of WMSCOG that you contend has been harassed as a result of the actions of the Defendant, as alleged in Paragraph 19 of the Complaint, and identify whether the individual is Still a member of WMSCOG, when they first became a member, when they left WMSCOG (if applicable) and describe any specific incidents of harassment, including Witnesses thereto.

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order. Plaintiff further objects to this Interrogatory on the grounds of Overbreadth and Undue Burden, as this Interrogatory seeks the private information of uninvolved, unrelated third parties, and therefore seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY NO. 9

Identify any and all grounds for your contention, in Paragraph 19 of the Complaint, that WMSCOG is “losing prospective membership because of Defendants’ conduct” and identify all lost business or members. Include in your answer an identification of (a) all persons with knowledge of the facts disclosed in your interrogatory answer; and (b) all documents (by Bates Number if applicable) referencing or reflecting such facts.

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order. Plaintiff further objects to this Interrogatory on the grounds of Overbreadth and Undue Burden, as this Interrogatory seeks the private information of uninvolved, unrelated third parties, and therefore seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

RESPONSE:

Subject to and without waiving its objections, Plaintiff states: Attendance and the number of Baptisms performed by the Church have decreased since the opening of the Website www.examiningthewmscog.com has opened. The Church’s growth rate has slowed, and attendance at speciñc ceremonies has decreased. Plaintiff reserves the right to supplement its response.

INTERROGATORY NO. 10

Identify any and all grounds for your contention, in Paragraph 20 of the Complaint, that WMSCOG “has lost prospective donative revenue from members, potential members and other benefactors.” Include in your answer an identiñcation of (a) all persons with knowledge of the
facts disclosed in your interrogatory answer; and (b) all documents (by Bates Number if applicable) referencing or reflecting such facts.

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order. Plaintiff further objects to this Interrogatory on the grounds of Overbreadth and Undue Burden, as this Interrogatory seeks the private information of uninvolved, unrelated third parties, and therefore seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

RESPONSE:

Subject to and without waiving its objections, Plaintiff States: see response to Interrogatory # 9. The Church’s loss of members and reduced growth rate has resulted in a loss of donative revenue.

INTERROGATORY NO. 11

Identify any lawsuit filed by or against any branch of WMSCOG since 2007. For each suit, describe the nature of the suit, the current status of the suit, the jurisdiction Where the suit is/was pending and the case number of the suit.

RESPONSE:

Plaintiff is not currently involved in any other lawsuits and has not been involved in any other litigation of any kind.

INTERROGATORY NO. 12

Identify any donation in excess of $1000 in a single donation or $10,000 cumulative annually. For each donation(s), identify the member or benefactor providing the donation, the date(s) of the donation and, if any, the specific use of the donation by WMSCOG (e.g., mission fund, building fund, general operations, etc.).

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order. Plaintiff further objects to this Interrogatory on the grounds of Overbreadth and Undue Burden, as this Interrogatory seeks the private information of uninvolved, unrelated third parties, and therefore seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY NO. 13

Identify all information discoverable under Rule 4:l(b)(4)(A)(l) ofthe Rules of Supreme Court of Virginia: identify any expert witnesses you intend to call at trial; state the subject matter on which the expert is expected to testify; identify the substance of the facts and opinions to which the expert is expected to testify; and provide a summary of the grounds for each opinion. Please also identify any correspondence or other communications to or from each such expert witness and identify any bibliographies or Writings authored by or relating to each such expert
witness.

OBJECTION:

Plaintiff objects to this Interrogatory as compound and constituting more than one Interrogatory.

RESPONSE:

Subject to and without waiving its objections, Plaintiff responds: Plaintiff has not yet obtained experts. Plaintiff reserves the right to supplement its response.

INTERROGATORY NO. 14

Identify each person providing information used to answer these Interrogatories and identify any documents used by said persons to answer the Interrogatories.

OBJECTION:

RESPONSE:

Subject to and without waiving its objections, Plaintiff identifies: Victor Lozada and Tara Byrne and Dov M. Szego and John W. Dozier, Jr. as counsel.

INTERROGATORY N0. 15

Identify any and all oral, written, or recorded statements obtained by you or on your behalf from any individual in connection with any of the allegations or defenses in this case. For each statement indicate the name, address, and occupation of the person who made the statement; the name, address and occupation of the person who obtained the statement; the date the statement was obtained; whether the statement is written or oral; if written: state the name and address of the person who has custody of the statement; if oral: state the substance of the statement; and if recorded: state the date and substance of the recording.

OBJECTION:

Plaintiff objects to this Interrogatory on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order. Plaintiff further objects to this Interrogatory on the grounds of Privilege and Work Product.

INTERROGATORY NO. 16

If you contend that Newton or Colon has made any admissions or declarations against interest concerning the facts or circumstances involved in this lawsuit, identify the statement(s) made, to whom such statement(s) was made, when and where such statement(s) was made, and the name and address of each person who may have heard the statement(s).

RESPONSE:

See Answer; see Affidavits provided by Michele Colon and Tyler Newton in support of Motion to Dismiss and Motion challenging jurisdiction.

INTERROGATORY NO. 17

Identify all persons with access to your Computer System, email system and software, backup system and software (including procedures, formats, and the location of backup storage media), and document retention/destruction practices. Identify all persons with whom you have shared your passwords to access these devices.

RESPONSE:

Subject to and without waiving its objections, Plaintiff identifies Victor Lozada. The Church does not have a backup system. Plaintiff reserves the right to supplement this response.

INTERROGATORY NO. 18

Identify all electronic documents that relate to or reference the subject matter of this action that have been deleted or overwritten Since this action was filed and state: (a) whether the deletion or overwriting was done through automation or by user action; and (b) what actions you have taken to restore the deleted or overwritten files.

RESPONSE:

Upon information and belief, no data has been deleted. Plaintiff reserves the right to supplement its response.

INTERROGATORY NO. 19

Identify how you learned of the closed Facebook Group described in Paragraph 27 of the Complaint and how you learned of the private statements made within the confines of that Group. State whether you or anyone known to you – and identify the means and methods that person used to gain access to the Group. Identify all Facebook account names used to access the Facebook Group, and the names of the persons who used these accounts.

OBJECTION:

Plaintiff objects to this Request on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order. Plaintiff further objects to this Interrogatory as compound and constituting more than one Interrogatory.

RESPONSE:

Subject to and without waiving its objections, Plaintiff states: Plaintiff was advised of the content of the Facebook Group by a Church member. Further response will be given following entry of an appropriate Protective Order. Upon information and belief no Church member is presently a member of the Facebook Group.

INTERROGATORY NO. 20

Please provide an itemized list of the particulars of every expense, financial loss, and/or other damage you contend you incurred as a result of the acts of Mr. Newton or for which you contend he is liable, including attorneys’ fees incurred in connection with this case. Identify the total amount of damages claimed and explain how that amount was calculated.

OBJECTION:

Plaintiff objects to this Request on the grounds of Proprietary Information. The information sought is sensitive, personal, and internal information that will be supplied only after entry of an appropriate Protective Order.
Plaintiff further states that its investigation in this matter is ongoing, and that it will supplement its response.

Dated: 5/16/12

WORLD MISSION SOCIETY, CHURCH OF GOD A NJ NONPROFIT CORPORATION
By: [Signature]
John W. Dozier, Jr., Esq.
VA Bar # 20559
Dozier Internet Law, P.C.
ll520 Nuckols Road, Suite 101
Glen Allen, VA 23059
Tel: (804) 346-9770
Fax: (804) 346-0800
email: [email protected]
Attorneys for Plaintiff World Mission Society, Church of God a NJ Nonprofit Corporation

VERIFICATION

State of NJ

County of Bergen

I am an agent of the Plaintiff authorized to endorse these Interrogatory responses. I certify that I have read the foregoing responses to Interrogatories and believe them to be true and correct.

[Signature] 5/16/12
Victor Lozada Missionary

[Notary Public Signature]

CERTIFICATE OF SERVICE

I hereby certify that on this 16th day of May, 2012, the foregoing PLAINTIFF’S FIRST OBJECTIONS AND RESPONSES TO DEFENDANT TYLER NEWTON’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS was transmitted to Lee E. Berlik, Esquire, Counsel for Defendants, via email to [email protected] and was deposited with the United States Postal Service as First Class Mail, postage prepaid, in an envelope addressed to:

Lee E. Berlik
BerlikLaw, LLC
1818 Library Street, Suite 500
Reston, VA 20190

[Signature]
John W. Dozier, Jr., Esq.

Dozier Internet Law, P.C.
11520 Nuckols Road, Suite 101
Glen Allen, Virginia 23060
Phone: (804) 346-9770
Fax: (804) 346-0800
email: [email protected]