Case 3:14-cv-00736-HTW-LRA Document 54-6 Filed 04/29/15 Page 1 of 4

WATSON & NORRIS, PLLC

Attorneys at Law

1880LAKELANDDRIVE,SUITEG
JACKSON,MISSISSIPPI39216

TELEPHONE:601.968.0000
FACSIMILE:601.968.0010

April 16, 2015

Via email: chuck@mcraelaw.net
Chuck R. McRae
416 E Amite Street
Jackson, MS 39201
Re:

State Farm v. Brandi Barnett

CA No.: 3:14cv736-HTW-LRA

Dear Mr. McRae:

I have reviewed the discovery responses of Ms. Martin, and several of them are
not adequate. First, Ms. Martin has raised numerous general objections to every
discovery request, which are improper. Baily v. Lockheed Martin Corp., 2006 U.S. Dist.
LEXIS 43651 *3-5 (S.D. Miss. June 12, 2006). Please withdraw these general
objections, and completely respond to any discovery request that was not answered
completely based on these general objections.
In Ms. Martins response to Interrogatory No. 1 she refers us to her pre-discovery
disclosures; however, the Interrogatory did not simply ask for identification. It also
asked for the general knowledge each person identified had that would be relevant to
the claims in the case. Please supplement this response with that information.
In Ms. Martins response to Interrogatory No. 2 she again refers us to her prediscovery disclosures. Ms. Martins pre-discovery disclosure only state that she is not in
possession of any documents. While that is clearly contradicted by what Ms. Martin has
stated so far in the litigation, the Interrogatory did not limit itself to documents in Ms.
Martins possession. Please supplement this response to identify any documents that
may be relevant that are not in Ms. Martins possession.
In Ms. Martins response to Interrogatory No. 5 she raises an objection to overly
broad and vague. This interrogatory is neither. Please withdraw these objections and
supplement this response to identify the facts that support Ms. Martins accusation that
Ms. Barnett seduced Precious Martin.
In Ms. Martins response to Interrogatory No. 8 she raises objections to overly
broad and outside the scoped of discovery. This interrogatory is neither as evidence of
other affairs would support the argument that Precious Martins affections had been lost
before even meeting Ms. Barnett, and would dispute any allegation that Ms. Barnett

EXHIBIT F

Case 3:14-cv-00736-HTW-LRA Document 54-6 Filed 04/29/15 Page 2 of 4

seduced Precious Martin. Please supplement this response by withdrawing the

objections and completely answering the question.
In Ms. Martins response to Interrogatory No. 9 she raises an objection to being
outside the scope of discovery. This interrogatory is relevant to show that Ms. Martin
and/or Precious Martin were engaged in sexual relationships with others excluding Ms.
Barnett. Please withdraw this objection and properly respond to the interrogatory.
In Ms. Martins response to Interrogatory No. 10 she raises an objection to being
outside the scope of discovery. Ms. Martin has alleged that Ms. Barnett has alienated
her from Precious Martins affections. Other insuance policies could be evidence to
dispute that claim. Moreover, these policies could dispute any claims for loss of aid and
emotional damages. Please withdraw this objection and properly respond to the
interrogatory.
In Ms. Martins response to Interrogatory No. 11 she raises objections based on
exceeding the scoped of discovery. This interrogatory is relevant as it seeks
discoverable information that may contain evidence regarding the affairs that Precious
Martin and/or Ms. Martin was involved in. It may also contain evidence regarding
emotional pain and suffering. Moverover, the Court has already ordered Ms. Martin to
sign a medical authorization, and it would be illogical for her to sign such a document
and refuse to identify the entities the medical authorization should be sent to. Please
withdraw this objection, and properly respond to the interrogatory.
In Ms. Martins response to Request No. 4 she raises objections based on being
overly broad and exceeds the scope of discovery. This request is not overly broad and
directly relates to Interrogatory No. 10, which has already been discussed. Please
withdraw these objections and produce the requested documents.
In Ms. Martins response to Request No. 5 she raises objections based on being
overly broad and exceeds the scope of discovery. This request is neither. The
documents are relevant to identify any other affairs of Precious Martin, and may dispute
any claims of loss of aid and emotional damages. Please withdraw these objections
and produce the requested documents.
In Ms. Martins response to Request No. 6 she raises objections based on being
overly broad and exceeds the scope of discovery. This request is not overly broad, and
is certainly relevant to identify other individuals that Precious Martin had an affair with,
and to dispute any claims of loss of aid and emotional damages.
In Ms. Martins response to Request No. 7 she raises objections based on being
overly broad, burdensome, and exceeds the scope of discovery. This request is
relevant to dispute any claims of loss of affection and emotional damages. The Court
has already ordered Ms. Martin to sign a complete medical waiver. Since the Court
has already ordered Ms. Martin to sign the waiver prior to our office even sending the
request it is clear Ms. Martin is violating an order of Court, and Plaintiff will seek
sanctions pursuant to Rule 37 of the Federal Rules of Civil Procedure if Ms. Martin
continues to refuse to sign the medical waiver and return it to our office.
Please supplement the responses to Ms. Barnetts discovery by April 20, 2015. If
Defendant Martin refuses to respond by this date, please execute and return the
attached good faith certificate.

Case 3:14-cv-00736-HTW-LRA Document 54-6 Filed 04/29/15 Page 3 of 4

s/Nick Norris
NICK NORRIS
NN/lp
Cc:

seth@mcraelaw.net
christopher@mcraelaw.net

Case 3:14-cv-00736-HTW-LRA Document 54-6 Filed 04/29/15 Page 4 of 4

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

GOOD FAITH CERTIFICATE

All counsel certify that they have conferred in good faith to resolve the issues in
question and it is necessary to file a Motion to Compel.
Counsel further certify:
___ (1)
The filed motion is unopposed by all parties.
___ (2)
The filed motion is unopposed by _______________.
_ (3)
The filed motion is opposed by Defendant.
___ (4)
The parties agree that the reply and rebuttal to the
filed motion shall be submitted to the Judge in accordance with the
time limitations set forth in Rule 7.2.
This, the 20th day of April 2015.

____________________________
Nick Norris, Esq.
Attorney for Plaintiff

____________________________
Chuck R. McRae, Esq.
Attorney for Defendant