Case 3:14-cv-00736-HTW-LRA Document 54-2 Filed 04/29/15 Page 1 of 10

UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
NORTHERN DIVISION
STATE FARM LIFE INSURANCE COMPANY
VS.

PLAINTIFF-COUNTER DEFENDANT

CIVIL ACTION NO. 3:14cv736-HTW-LRA

CRYSTAL WISE MARTIN AND

BRANDI BARNETT

DEFENDANTS- COUNTER PLAINTIFF

DEFENDANT BRANDI BARNETTS FIRST SET OF INTERROGATORIES AND

REQUESTS FOR PRODUCTION OF DOCUMENTS TO
DEFENDANT CRYSTAL WISE MARTIN

COMES NOW Defendant Brandi Barnett by and through her attorney, and
propounds these Interrogatories and Requests for Production of Documents to
Defendant Crystal Wise Martin to be answered in accordance with the Federal Rules of
Civil Procedure. Defendant Martin shall please produce the responses requested at the
offices of Watson & Norris, PLLC, 1880 Lakeland Drive, Suite G, Jackson, Mississippi
39216 within 30 days of service.
General Instructions
1.

If any of these interrogatories cannot be answered in full, then Defendant

should answer to the extent possible and specify the reasons for his
inability to answer the remainder, and should state whatever information
or knowledge he has concerning the unanswered portion. For example, in
answer to the interrogatories concerning witnesses and documentary
evidence, please identify as many witnesses and proposed exhibits as
possible, rather than stating "unknown at this time."

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EXHIBIT B

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2.

In answering these interrogatories, please furnish such information as is

known or is available to Defendant, regardless of whether this information
is obtained directly by, or known to, or obtained by, any of his attorneys or
other agents or representatives.
Definition of Terms

3.

Throughout these interrogatories, including the definition of terms, the

words used in the masculine gender include the feminine; and words used
in the singular include the plural. Where the word "or" appears herein, the
meaning intended is the logical inclusive "or" i.e., "and/or." Where the
word "include" or "including" appears, the meaning intended is "including
but not limited to."

4.

As used throughout these interrogatories, the following terms have the

following meanings indicated:
(a)

"Date" means the exact day, month and year, if ascertainable, or if

not, the best approximation (including relationship to other events).

(b)

"Person" means any individual, corporation, proprietorship,

partnership, association or any other entity.

(c)

"Document," as defined by Rule 34 of the Federal Rules of Civil

Procedure, includes all writings, drawings, graphs, charts,
photographs, phone records, tape recordings, and other data
compilations from which information can be obtained or translated.

(d)

"Identify" when referring to a person, as defined above, means to

state the following:

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(1)

The name of that person;

(2)

The address of that person;

(3)

If the present residence or business address is unknown,

state the last known address and any other information you
have that might reasonably lead to that person being
located;

(4)

The telephone number for that person (home and business

where applicable) or that person's last known telephone
number;

(5)

If that person is an individual, state his employer, his position

with and duties for that employer and the address of that
employer.

(e)

"Identify" when referring to a document, as defined above, means

to please produce the following information:
(1)

The date of the document;

(2)

The title of the document;

(3)

The identity of the person by whom the document was

prepared;

(4)

The identity of the person for whom the document was

prepared;

(5)

The subject matter covered by the document;

(6)

The present location of the document;

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(7)

The custodian of the document, including his name,

address, and business telephone number.

(f)

"Identify" when referring to an oral communication (report) means

to Please produce:
(1)

The date of the report;

(2)

Identify the person by whom the report was made;

(3)

Identify the person to whom the report was made;

(4)

Identify persons who witnessed or heard the report, or in

whose presence the report was made;

(g)

(5)

State where the report was made;

(6)

State the contents of the report.

"Description" or "to describe" means to please produce a narrative

detailed chronological history of the incident or event(s) inquired
about, including pertinent dates, identifying persons involved, and
identifying documents utilized or generated.
INTERROGATORIES

INTERROGATORY NO. 1:
Identify by name, address, telephone number and present employer each and
every person Defendant Martin believes has knowledge of any facts relevant to
Defendants Martins claims in this action. For each such individual identified, describe
what knowledge you believe said individual has.

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INTERROGATORY NO. 2:
Identify all documents which in any way support, pertain to, or relate to the
subject matter of this lawsuit or the Defendant Martins claims against Defendant
Barnett.
INTERROGATORY NO. 3:
Identify each person expected to be called as a witness at trial.
INTERROGATORY NO. 4:
Identify all people you have discussed this litigation with and identify those from
whom you have obtained a written or recorded statement regarding this litigation.
INTERROGATORY NO. 5:
Please explain in detail each and every fact or event of which Defendant Martin
is aware which support her allegation that Defendant Barnett seduced Precious Martin.
INTERROGATORY NO. 6:
Are you aware of the existence of any written or recorded statement(s) made by
or for any party or witness pertaining to the facts of this case? If so, state:
(a)

The name of each person making the statement;

(b)

The date of the statement;

(c)

The name, employer, occupation, last known address, and telephone

number of the person taking the statement;

(d)

The name and last known address and telephone number of the person
now in possession of the original statement or a copy of same.

INTERROGATORY NO. 7:

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Did your attorney or anyone acting on your behalf conduct an investigation

concerning the subject incidents regarding Defendant Barnett? If so, please state the
name, address, and telephone number of the person now having custody of each
written report made concerning each investigation.
INTERROGATORY NO. 8:
Please identify all persons whom Defendant Martin knows had a sexual
relationship with Precious Martin in the past ten (10) years.
INTERROGATORY NO. 9:
Please identify all sexually transmitted diseases Defendant Martin has
contracted, and whom they were contracted from since her marriage to Precious Martin.
If any sexually transmitted disease was contracted from Precious Martin please also
identify whom he contracted the sexually transmitted disease if known.
INTERROGATORY NO. 10:
Please identify all life insurance policies that Precious Martin had in place at the
time of his death. Please include the (1) when the insurance was purchased, (2) the
insurance company and policy number, (3) the amount of life insurance provided, and
(4) the beneficiaries for each policy.
INTERROGATORY NO. 11:
Identify by name, address, and telephone number (including area code) all
hospitals, medical doctors, psychiatrists, psychologists, counselors and other medical
and/or mental healthcare personnel you have contacted, visited, or received treatment
in the last ten (10) years.

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REQUESTS FOR PRODUCTION OF DOCUMENTS

REQUEST NO. 1:
Please produce all documents identified in response to the foregoing
interrogatories.
REQUEST NO. 2:
Please produce copies of any recordings, audio-tapes, email or videotape that
Defendant Martin has in her possession involving the Defendant Barnett.
REQUEST NO. 3:
Please produce documentation that justifies your claim that Defendant Barnett
was not entitled to the proceeds of the insurance policy in question.
REQUEST NO. 4:
Please produce all documents related to life insurance policies that Precious
Martin had at the time of his death.
REQUEST NO. 5:
Please produce all documents relating to the estate of Precious Martin.
REQUEST NO. 6:
Please produce all bank statements for Defendant Martin, Precious Martin, and
any corporation owned by either individual for the past three (3) years.
REQUEST NO. 7:
Please execute and return the attached HIPAA release.
This, the 9th day of February 2015.
Respectfully submitted,
s/Nick Norris
NICK NORRIS (MB# 101574)
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OF COUNSEL:
WATSON & NORRIS, PLLC
1880 Lakeland Drive, Suite G
Jackson, Mississippi 39216
(601) 968-0000
Fax: (601) 968-0010
nick@watsonnorris.com

CERTIFICATE OF SERVICE
I, Nick Norris, attorney for the Plaintiff, do hereby certify that I have this day
served via ECF filing or by United States mail, postage prepaid, a true and correct copy
of the above and foregoing document to the following counsel of record:
Chuck R. McRae
416 E Amite Street
Jackson, MS 39201
chuck@mcrawlaw.net

SO CERTIFIED, this the 9th day of February 2015.

s/Nick Norris
NICK NORRIS.

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HIPAA COMPLIANT AUTHORIZATION FOR USE AND DISCLOSURE

OF INDIVIDUALLY IDENTIFIABLE HEALTH INFORMATION

Person/Entity from Whom

Records are Requested:
Provider Name

Address City, State and Zip Code

Patient:

CRYSTAL WISE MAARTIN

Patient Name

Date of Birth

Social Security Number

Information Authorized To Be Disclosed: I authorize the Provider to furnish copies of my

entire medical record and all of my individually identifiable health information, including,
without limitation:
medical reports blood tests radiographic films CT scans X-rays MRI films MRA films
correspondence progress notes prescription records echocardiographic recordings
written statements employment records wage records disability records billing statements
pathology specimens
and other documents in your possession including records from other providers, including
records for treatment of psychological, psychiatric or emotional problems, during the time period
from August 18, 2002 until the date of this Authorization, to the following representative of the
Defendant in the litigation styled Mokhtar Aouina v. Jackson State University, United States
District Court, Southern District of Mississippi, Civil Action No. 3:13CV243:
Person To Whom Records Nick Norris, Esq.
Are To Be Disclosed:
Name of Representative (Requestor)
Attorney for Plaintiff
Representative Capacity
1880 Lakeland Drive, Suite G, Jackson, MS 39216
Address City, State and Zip Code
The records requester has agreed to pay reasonable charges made by the Provider to supply
copies of such records.

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Purpose of Disclosure: I am requesting this disclosure to allow these records to be used in

connection with the litigation mentioned hereinabove.
Acknowledgments:
I understand that this disclosure may include information relating to treatment of drug or
alcohol abuse, mental health, psychiatric information, acquired immunodeficiency
syndrome(AIDS), human immunodeficiency virus (HIV), sexually transmitted diseases, sickle
cell anemia treatment, tuberculosis information, and genetic testing information.
I understand that if the persons or entities to whom I am asking that the Provider disclose
this information are not covered by federal privacy regulations, then this information will no
longer be protected under federal privacy law and could be subject to re-disclosure.
I understand that my signing or revocation of this authorization will not affect my health
care treatment or eligibility for payment under my health plan.
Term and Revocation: This authorization shall be considered as continuing in nature until a
final, non-appealable judgment has been entered in the case I have brought. This authorization
remains in full force and effect until such expiration, and further authorizes the Provider to
release to the Requestor any additional records created or obtained by the Provider after the date
hereof. I understand that I may revoke this authorization at any time by writing to the Provider at
the Providers above address, but my revocation will not apply to information that has already
been released before the Provider receives notice of any revocation.
It is expressly understood by me that the Provider is authorized to accept a copy or
photocopy of this authorization with the same validity as though an original had been presented
to the Provider.

Date: _________________________

____________________________________
Signature of Patient or Personal Representative

Date: _________________________

____________________________________
Witness Signature