Kimberly A. Chandler, VSB# 47897

Richard C. Pecoraro, VSB# 48650

CHANDLER PECORARO, PLC

P.O. Box 17586

Richmond, VA 23226

Office: (804) 545-0737

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: Jeffrey M. Sober, Case No. 15-31693-KLP

Janice M. Sober

Debtors,

Chapter 13

C. I. ASSOCIATES, L.P.,

Plaintiff,

v. Adv. Pro No. 15-03382-KLP

JANICE M. SOBER,

Defendant.

SECOND SET OF INTERROGATORIES, ADMISSIONS AND REQUESTS FOR 

PRODUCTION OF DOCUMENTS

COMES NOW Janice M. Sober (“Debtor”), by counsel, pursuant to Rules 26, 33 and 34 

of the Federal Rules of Civil Procedure, incorporated by FED.R.BANKR.PROC. 7026, 7033 and 

7034, to request the Plaintiff to answer the following interrogatories under oath, in writing, 

separately and in the fullest detail possible, to respond to requests for Admissions, and to 

produce certain specified documents. 

Each interrogatory shall be answered separately and fully in writing under oath, and shall 

be signed by the persons making them. A copy of the responses shall be served prior to the 

hearing on the merits of this matter.

You are under a duty pursuant to FED.R.CIV.PROC. 26(e) to seasonably supplement or 

correct your response with respect to (1) any incomplete or incorrect information; and (2) with 

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respect to the testimony of an expert witness, any incomplete or incorrect information contained 

in an expert report or in the deposition testimony of the expert. You are under a duty to 

seasonably amend a prior response if you obtain information upon the basis of which (1) you 

know that the response was incorrect when made, or (2) you know that the response though 

correct when made is no longer true, and the circumstances are such that a failure to amend the 

response is in substance a knowing concealment. 

DEFINITIONS

Complaint. As used in this discovery, “Complaint” means the subject of this 

Adversary Proceeding No.10-03008-KRH, the Complaint filed by David Scott Milliron, against 

[Docket No. 1].

Document. As used in this discovery, the term "document" means any tangible medium 

upon which information or data can be communicated, recorded or retrieved, whether set down 

by handwriting, typewriting, printing, photocopying, photographing, magnetic impulse, 

mechanical or electronic recording, electronic mail or any other form of data compilation, that is 

in your possession, custody or control or which was, but is no longer, in your possession, custody 

or control. The term "document" includes, without limitation, the original and each duplicate, 

regardless of origin and location, of any book, pamphlet, periodical, letter, memorandum, 

invoice, bill, order form, receipt, financial statement, accounting entry, diary, calendar, telex, 

email, telegram, cable, report, record, contract, agreement, study, hand-written note, draft, 

working paper, chart, paper, print, laboratory record, drawing, sketch, graph, index, list, tape, 

tape recording, photograph, microfilm, or data sheet, in electronic or ordinary form.

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Duplicate. As used in these interrogatories, a "duplicate" is a counterpart produced by 

the same impression as the original, or from the same matrix, or by means of photography, 

including enlargements and miniatures, or by mechanical or electronic re-recording, specifically 

including electronic copies of computer files, or by chemical reproduction, or by other equivalent 

techniques that accurately reproduces the original.

Occurrence. As used in these interrogatories, the term "occurrence" refers to the time, 

place and circumstance of the occurrence, incident, event or transaction mentioned or 

complained of in the pleadings, unless otherwise indicated.

Identification, Identify, Identity. As used in these interrogatories, the terms 

"identification," "identify," or "identity," when used in reference to:

(a) a natural individual, require you to state his full name, residential and business 

addresses, and residential and business telephone numbers;

(b) a corporation, require you to state its full corporate name and any names under 

which it does business, the address of its principal place of business and the telephone 

number of its principal place of business;

(c) a business or other unincorporated organization, require you to state the full name 

or style under which the business is conducted, its business address or addresses, its 

telephone number or numbers the types of business in which it is engaged, and the 

identity of the person or persons who own, operate, and control the business; 

(d) a document, require you to state the nature of the document (e.g., letter or 

memorandum), its title, its date, the identity of its authors and recipients, a brief 

description of its contents, and the identity of its present custodian.

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Or. As used in these interrogatories, the word "or" should not be read so as to eliminate 

any part of the interrogatory in which it appears, but, whenever applicable, it should have the 

same meaning as the word "and". For example, an interrogatory stating, "support or refer" 

should be read as "support and refer" if an answer that does both can be made.

Original. As used in these interrogatories, an "original" of a writing or recording is the 

writing or recording itself or any counterpart intended to have the same effect by a person 

executing or issuing it. An "original" of a photograph includes the negative or any print there 

from. If data are stored in a computer or similar device, any printout or other output readable by 

sight, shown to reflect the data accurately, is an "original", as is an electronic copy of the 

computer file from which such a printout may be made.

Person. As used in these interrogatories, the term "person" means any natural individual 

and any entity or organization, including divisions, departments, and other units, and includes, 

without limitation, a public or private corporation, partnership, limited partnership, joint venture, 

voluntary or unincorporated association, organization, proprietorship, trust, estate, governmental 

agency, commission, bureau, or department.

Photographs. As used in these interrogatories, the term "photographs" includes still 

photographs, X-ray films, videotapes, and motion pictures. The term also includes computer 

files that will, with appropriate processing, result in a "photograph" as the term is herein defined.

Representative. As used in these interrogatories, the term "representative" means any and 

all agents, employees, servants, officers, directors, attorneys, or other persons acting or 

purporting to act on behalf of the person to which these interrogatories are directed.

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Statement. As used in these interrogatories, the term "statement" means communication 

in any form and includes written and oral communications. A written communication, as used in 

these interrogatories, is a document as defined above. An oral communication includes, but is 

not limited to, telephonic communications.

You, Your, or Yourself. As used in these interrogatories, the terms, "you", "your", and 

"yourself" refer to the person upon whom/which these interrogatories have been served, each of 

his agents, representatives, and attorneys, and each person acting or purporting to act on his 

behalf. With respect to the defendants, it means each individual defendant unless (and only if) 

the answer to the interrogatory is the same for both defendants, in which case a joint answer may 

be made. Specifically, the term “you” and “your” means Wachovia Bank, National Association 

and any successor-in-interest.

If you contend that you are entitled to withhold from production any document identified 

in these interrogatories on the basis of attorney-client privilege, the work-product doctrine, or 

any other grounds, then describe the nature of the document (e.g., letter, memorandum), state the 

date of the document, identify the person or persons who sent or received the original or any 

copies of the document, state the title of the document and describe its subject matter (without 

revealing the information as to which the privilege is claimed), and state the factual and legal 

basis, including specific statutory authority, upon which you contend you are entitled to withhold 

the document from production.

INTERROGATORIES

1. Please identify yourself, and each person with whom you consulted, upon whom 

you relied, or who otherwise constituted a source of information to you in connection with the 

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preparation of your responses to these interrogatories and, with respect to each person that you 

identify, list the numbers of the interrogatories to which he or she helped prepare the responses 

or with respect to which he or she was consulted, relied upon or otherwise constituted a source of 

information.

ANSWER:

2. Please identify Laura Stephens, her relationship to the case, her current position, 

current employer including start dates, her past employment at it related to these proceedings, 

starting July 1, 2005 to present, all persons upon whom she relied to prepare any probative evidence 

to support any claims from CIA, LP, against Janice Sober. Further, identify the matters and areas 

to which Ms. Stephens has responsibility in her position (be it past or present with Creditor), and 

state her relationship to or direct contact with Debtor and include the facts and circumstances 

known to her that bear on any allegations against Mrs. Sober, inclusive of dates when those 

matters arose. Also, identify any depositions, sworn statements, affidavits or expert reports or 

opinions by Laura Stephens.

ANSWER:

3. Please identify all documents, records, compilations of records and 

correspondence, or emails and or electronic communications relating to the allegations against 

Mrs. Sober and all exhibits thereto and for each, state the date, the existence of such that were 

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prepared by or relied upon by Laura Stephens, and the preparer and/or author of each and the 

circumstances to which they relate to the allegations of the against Mrs. Sober.

REQUESTS FOR ADMISSIONS

Please admit that:

A. Laura Stephens, did not testify under oath as to the facts at the default hearing 

for Prince George Circuit Court Case No. CL07000095-000.

RESPONSE:

B. No depositions, sworn statements, or affidavits by Laura Stephens, were offered 

at the default hearing for Prince George Circuit Court Case No. CL07000095-000.

RESPONSE:

C. No depositions, sworn statements, or affidavits, were offered at the default

hearing for Prince George Circuit Court Case No. CL07000095-000.

RESPONSE;

D. No depositions, sworn statements, or affidavits of witnesses were in the 

possession of Counsel when he filed Adversary Proceeding No. 15-03382-KLP, on July 3, 2015. 

RESPONSE;

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E. No expert reports or opinions were in the possession of Counsel when he filed 

Adversary Proceeding No. 15-03382-KLP, on July 3, 2015. 

RESPONSE;

F. No expert reports or opinions currently exist prepared by Laura Stephens or any 

other party as related to the allegations herein. 

RESPONSE;

G.. In Prince George Circuit Court Case No. CL07000095-000., no proof of service 

exists against Janice M. Sober.

RESPONSE:

REQUESTS FOR PRODUCTION OF DOCUMENTS

1. Produce all documents identified or related to your responses to the 

foregoing First Set of Interrogatories and Requests for Admissions.

2. Produce all documents relied upon, or to be relied upon, by any witness you 

might expect to call as a witness in the Adversary 15-03382-KLP trial of the Debtor and 

the Defense of Debtors Objection to C.I. Associates, L.P., proof of claim [Docket No. 40].

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3. Produce a full and complete copy of Laura Stephens, files, documents, 

electronic mails or records of communications regarding the subject matter of the 

objection or the Complaint; the litigation of the Circuit Court case; settlement proposals; 

discovery; and any other matter, relevant or not, concerning the allegations. Debtor does 

not seek privileged or confidential information between lawyer and client but explicitly 

requests non-privileged files, documents or electronic mails including those provided to 

third parties or which are records of communications at which a third party were present 

in person or by electronic means.

4. Produce a full and complete breakdown of the alleged amounts due and 

owing CIA, LP, including the dates inclusive therein said amounts representing in total 

$35,600.00, being the same as those in Case No. CL07000095-000. 

5. Produce a full and complete breakdown of the alleged amortization 

schedule used to calculate interest due and owing CIA, LP, including the dates inclusive 

therein said amounts representing in total $$21,544.88, as identified in CIA, LP., Claim 

No. 10.

Respectfully submitted, this the 25th day of September, 2015.

/s/ Kimberly Chandler

Kimberly Chandler

Chandler & Pecoraro, PLA

7113 Three Chopt Road, Suite 201

Richmond, Virginia 23226

Counsel for Janice M. Sober

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CERTIFICATE OF SERVICE

I, the undersigned, do hereby certify that on this day a true and correct copy of 

defendant’s second set of interrogatories, admissions and requests for production of 

documents were transmitted by the Court’s ECF facility addressed to: 

W. R. Baldwin, III

Meyer, Baldwin, Long & Moore L.L.P.

5409 Patterson Avenue, Ste 101

Richmond, VA 23226

/s/ Kimberly Chandler

Kimberly Chandler

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