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Cynthia Atchison
9 Beech Street
Augusta, Mt 59410
406-562-3781

MONTANA FIRST JUDICIAL DISTRICT COURT,

LEWIS AND CLARK COUNTY

Dept. No 3
) Your Case No. CDV-2016-S47

Plaintiff, )
) Defendants Responses To
vs. ) Plaintiff's First Combined
wrY'lj A,-\c h,\ :OY'l '.
Discovery Requests To Defendant

l
CYNTHIA ATCHISON
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 1 INTERROGATORIES

2 INTERROGATORY NO.1: Please identify yourselffully by stating your full name,

3 including any other aliases you have ever gone by, your date of birth, occupation,

4 residence, and business address, setting forth occupation, residence, and business

5 address at the date of the abuse alleged, if they differ from your present occupation and

6 address, ~.n-\n\~ t-~ nl\ A \eN~ 0( "Deeah '3-tee={

1\ Af\~"" 1)D~ 'g ~,~ lp'S Qu_"tt-t~h1 Y\!IT
7 ANSWER: \~ stcx-cd~ ~ \Dvy'CtJ,,5t-rLe_.\
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8 INTERROGATORY NO.2: Please list any and all of your previous residential

9 addresses, the dates in which you lived at these addresses, and the names and

·10 telephone numbers of any co-residents who lived at these addresses while you lived
\ Q <6'S \q~ ~', \ ~'5 ~~\~e_ %l~(JL.\) ~I ~~ \\~

11 there.
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12 ANSWER: \ C\q(R. prcstq')[ Y 't>c:e.ct\ Strc~\ Q.w_ql/l')-in

13 INTERROGATORY NO.3: If you have any insurance agreements, contracts or

14 policies that might provide coverage as to the occurrences and allegations that are the

15 subject of this lawsuit, please list and describe each of the policies, including policy

16 numbers and limits. [lvvvevi (_c~"\. MW~"Y') ~-e. 9t>\\Clf .....

)
Po~ S~[.....~ L{~n~h OH eooq \300Z.t>
17 INTERROGATORY NO.4: If your resP6~~zeto'fhWf)receding Interrogatory was

18 in any respect in the affirmative, please state whether any of the insurance carriers

19 identified have claimed or are claiming that insurance coverage for the occurrences and

20 allegations that are the subject of this lawsuit is or might be excluded from coverage for

21 any reason and provide a detailed description of the reasons for the exclusion or

22 possible exclusion,

PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS PAGE 8 OF 15

TO DEFENDANT CYNTHIA ATCHISON
 2 INTERROGATORY NO.5: Please outline each and every loan you applied for

3 from the date of the alleged abuse to the present, including lender information.

4 ANSWER: "D'r\e__ I(!)~

5 INTERROGATORY NO.6: Please identify by name, residential address, and

6 phone number any witnesses who may have any knowledge of the allegations

7 contained in the Complaint and/or Answer and/or knowledge of any of the events or

8 happenings related to this lawsuit.

9 ANSWER: \~D\~Z

10 INTERROGATORY NO.7: Please state whether you, your attorney, your

11 agents or investigators, or anyone acting on your behalf or on behalf of your attorney,

12 agents or investigators, have obtained statements in any form from any person

13 regarding any of the events or happenings related to this lawsuit, and if so, please

14 provide the names and addresses of the person or persons from whom any such

15 statement(s) was taken, the date(s) on which such statement(s) was taken and the

16 names and addresses of any persons having custody of such statement{s}.

17 ANSWER: -:I nO,..

A)-<:'__ WD Pr\-\-ovY)e'~ 0V' ~el\,t
18 INTERROGATORY NO.8: Are you now, or have you ever been married?

19 ANSWER: L\~)
20 INTERROGATORY NO.9: If the answer to the preceding interrogatory is in the

21 affirmative, please state as to each marriage:

\)~A\~ "'£_ l0Pt\¥--e( -
22 (a) the date and place where you were married, Iq ts ~ th \ \ e 1'1\
\qqC\ ~L{~

PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS I.-o-v-Y'j J LVA\\Le.1 PAGE90F 15

TO DEFENDANT CYNTHIA ATCHISON
 1
(b) the full name and contact information for each spouse (including maiden
2 name), 'DC:W\'R-\l\ ~ Wi\.\\0t-( ~~ \~tb LL,,'LY'llX.r0lf\
. e....-"i- e..ep\ r-~ L\ ~ e.$ ()...) LO \' "S-D-:nv-,
3 (c) date and place of each dissolution.
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4 ANSWER:

5 INTERROGATORY NO.1 0: Have you ever been convicted of, plead guilty to, or

6 plead no contest to, a felony or misdemeanor criminal offense?

7 ANSWER:

8 INTERROGATORY NO. 11: If the answer to the preceding interrogatory is in the

9 affirmative, please state with regard to each such conviction:

10 (a) the nature of the crime,

11
(b) the date of the conviction,
12
(c) the name and address of the court, including number, street, city or
13 town, and state,

14 (d) the sentence,

15 (e) if you were imprisoned, the name and address of the jail, including
number, street, city or town, and state,
16
(f) if you were paroled, the date of parole and name and address of your
17 parole officer.

18 ANSWER: 0 \A-
19 INTERROGATORY NO. 12: Please state the date on which you purchased the

20 mobile home located at 109 Beech Street, Augusta, Montana 59410 and the dates in

21 which you lived in this home.

22 ANSWER: (-\ \)f1 \ \ qqL,

PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS PAGE 10 OF 15

TO DEFENDANT CYNTHIA ATCHISON
 1 INTERROGATORY NO. 13: Please describe with detail and with specificity the

2 dates that Larry Atchison resided at this 109 Beech Street residence and the dates that

3 the Plaintiff, Tara Walker Lyons, resided at the 109 Beech Street residence.

4 ANSWER: \\~\ \ v::V~~ - \)f C 6e \1.....,.4, . \....a '(I{~ A \c'h\S>d\

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5 INTERROGATORY NO. 14: Please describe in detail and with specificity how

6 often the Plaintiff, Tara Walker Lyons, stayed at the 109 Beech Street residence, as

7 compared to how often she stayed with her father Donald Walker, pursuant to the

8 parenting plan between you and Donald Walker.

9 ANSWER: LAn 'L"O-u~

10 INTERROGATORY NO. 15: Please describe in detail and with specificity the

11 contents of any and all conversations you had with the Plaintiff, Tara Walker Lyons,

12 about Mr. Atchison's inappropriate and illegal conduct towards her and the approximate

13 dates on which these conversations occurred.

14 ANSWER: \J-_x\. ~Gv-\~

15 INTERROGATORY NO. 16: Please describe in detail and with specificity the'

16 contents of any and all conversations you had with Mr. Atchison pertaining to Mr.

17 Atchison's inappropriate and illegal conduct towards the Plaintiff, Tara Walker Lyons,

18 and the approximate dates on which these conversations occurred.

19 ANSWER: \.A.Y\ \Lt! bl.._..0v'\

20 INTERROGATORY NO.17: Please describe in detail and with specificity any and

21 all actions that were taken (if any were taken) to protect the Plaintiff, Tara Walker Lyons,

22 from the inappropriate and illegal conduct of Mr. Atchison.

PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS PAGE 11 OF 15

TO DEFENDANT CYNTHIA ATCHISON
 1 ANSWER: U,_.,(\ \( """" ~

2 INTERROGATORY NO. 18: Please describe in detail and with specificity how

3 much alcohol you and Mr. Atchison typically consumed during a typical week while the

4 Plaintiff, Tara Walker Lyons, was under your care and custody.

5 ANSWER: ~ knC>v<.'N\
6 INTERROGATORY NO. 19: Please describe in detail and with specificity how

7 often you and Mr. Atchison went to bars and other public places to consume alcohol

8 while the Plaintiff, Tara Walker Lyons, was under your care and custody.

9 ANSWER: (\me.
10 INTERROGATORY NO. 20: Please describe in detail and with specificity how

11 often you would leave the Plaintiff, Tara Walker Lyons, alone and unsupervised, in the

12 custody of Larry Atchison.

13 ANSWER: \JO)(le_

14 INTERROGATORY NO. 21: If the Answer to the preceding interrogatory

15 indicates that the frequency of these unsupervised time periods changed over time,

16 please describe in detail and with specificity the reason these time periods changed.

17 ANSWER: N IA
18 INTERROGATORY NO. 22: To the extent any of your responses to the Requests

19 for Admission below are full or partial denials, please state the basis of your denials.

20 RESPONSE: rJ I~
21

22

PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS PAGE 12 OF 15

TO DEFENDANT CYNTHIA ATCHISON
 1 REQUESTS FOR PRODUCTION

2 REQUEST FOR PRODUCTION NO.1: Please produce any and all documents

3 and other tangible items supporting or in any way related to your Answer to Interrogatory

4 NO.3 including, but certainly not limited to, policies, declaration pages, notes, memos,

5 investigative reports, evaluations, emails and other correspondence of any kind or

6 nature.
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7 RESPONSE: 7\0...\ (\Tl \ ,"S J
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8 REQUEST FOR PRODUCTION NO.2: Please produce any and all documents

9 and other tangible items supporting or in any way related to your Answer to Interrogatory

10 No. 12. \\\ Dt Pr\){\\\o._C)~e_ ~ -\ -\vv\ ":)-\--\~~

11 RESPONSE:

12 REQUEST FOR PRODUCTION NO.3: Please provide a copy of any and all loan

13 applications and any and all other documents that list in detail any assets that you

14 currently own, including but certainly not limited to statements documenting monies in

15 bank accounts, shares in stocks and bonds, and titles to real property.

16 RESPONSE: ~ 0+ Au\J\1 \a_~l ~ -A -\ -t-\vV\-e

--\-1A\ "":)

17 REQUEST FOR PRODUCTION NO.4: If the answer to Interrogatories 10 and

18 11 were in the affirmative, please provide any and all documentation of your arrests and

19 subsequent court proceedings, including but not limited to documents that detail your

20 arrests, court appearances, incarceration, probation, parole, and release.

21 RESPONSE: ~O~e__
22

PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS PAGE 13 OF 15

TO DEFENDANT CYNTHIA ATCHISON
 1 REQUEST FOR PRODUCTION NO.5: Please produce a true and complete

2 copy of the parenting plan between you and Donald Walker.

3 RESPONSE: ~ A \~ WA\\(_~ ~ ~ frO. f~ (t~'S~l1

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4 N. REQUESTS FOR ADMISSION

5 REQUEST FOR ADMISSION NO.1: Please admit that you left the Plaintiff, Tara

6 Walker Lyons, under the sole, unmonitored, care and supervision of co-Defendant Mr.

7 Atchison, on numerous occasions while you, Mr. Atchison, and the Plaintiff resided at

8 the 109 Beech Street residence.

9 ANSWER~.u...\

10 REQUEST FOR ADMISSION NO.2: Please admit that the Plaintiff, Tara Walker

11 Lyons, informed you that Mr. Atchison had touched and/or caressed the Plaintiff in a

12 sexual manner numerous times between 1994 and 2001, while the Plaintiff was a minor

13 child, under the age of 18, and still under your care and custody.

14 ANSWER: \)eN\.,-\

15 REQUEST FOR ADMISSION NO.3: Please admit that despite the fact that the

16 Plaintiff informed you that she was being sexually abused by Mr. Atchison, you failed to

17 act to stop the abuse from occurring.

18 ANSWER: ))el~

19

20

21

22

PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS PAGE 14 OF 15

TO DEFENDANT CYNTHIA ATCHISON
 r->
1 DATED this Ji_ day July, 2017.

2 DATSOPOULOS, MacDONALD & LIND, P.C.

5
By: ·lJi-iJ
~IIY K. Howard
Attorneys for Plaintiff
6

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PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS PAGE 15 OF 15

TO DEFENDANT CYNTHIA ATCHISON
 VERIFICATION

STATE OF MONTANA

County of lewis and Clark

Cynthia Atchison, being first duly sworn, depose and say; That she is the Defendant in this case;
that she has read the foregoing Defendant's Responses to Plaintiffs First Combined Discovery Requests
to Defendant and knows the contents thereof, and that the matters and things therein stated are true to
her best knowledge, information and belief.

cYf( ta Atchison

SUBSCRIBED and SWORN to before me thisdlt'-day of September, 2017

TERRI lORENZ
sJ~~
NOTARY PUBLIC for the
State of Montana
Residing at Helena, Monll;:,:i
My Commission ExIIires
March 31,201 B