Case 3:14-cv-00736-HTW-LRA Document 54-5 Filed 04/29/15 Page 1 of 8

IN THE UNITED STATES DISTRICT COURT

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

PLAINTIFF/COUNTER DEFENDANT
CAUSE NO. 3:14-CV-736 HTW-LRA

VS.

CRYSTAL WISE MARTIN

BRANDI BARNETT

DEFENDANTS/COUNTER PLAINTIFF

DEFENDANT CRYSTAL WISE MARTIN'S RESPONSES TO DEFENDANT BRANDI

BARNETT'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS

COMES NOW, the Defendant, Crystal Wise Martin, by and through counsel, and responds
to Defendant's First Set of Interrogatories and Requests for Production of Documents.

GENERAL OBJECTIONS
(1)

Defendant objects the discovery requests to the extent that they incorporate or set forth
definitions, instructions, or requirements that attempt to impose upon Defendant burdens
and obligations beyond those contemplated by the Federal Rules of Civil Procedure.
Defendant will respond as required by the applicable provisions of the Federal Rules of Civil
Procedure and any purported instructions, definitions, requirements, or requests to the
contrary will be disregarded.

(2)

Defendant objects to these discovery requests to the extent that they seek information
protected by attorney-client privilege or work product doctrine.

(3)

To the extent any requests can be interpreted as requiring Defendant to identify or produce
any document or set forth any information which is in the possession, custody, or control of
Defendant Barnett or otherwise, that has been available to or is otherwise not in the

EXHIBIT E

Case 3:14-cv-00736-HTW-LRA Document 54-5 Filed 04/29/15 Page 2 of 8

possession of Defendant, or is equally accessible to Defendant Barnett, Defendant objects

hereto.
(4)

Defendant objects to these requests to the extent that they seek documents or information
not relevant to the subject matter of this action and not reasonably calculated to lead to the
discovery of admissible evidence.

(5)

Defendant has not completed discovery, investigation, or preparation for trial in this matter.
Accordingly, documents and information are provided without prejudice to Defendant
Barnett's rights to make further objections and present additional information and
documents which are hereafter discovered or which further discovery and investigation may
indicate are relevant to this action and called for by Defendant Barnett.

(6)

These general objections apply to each and every one of the following responses and
objections, and failure to repeat an objection in response shall not be deemed a waiver of
these general objections.

(7)

Defendant reserves the right to further supplement these responses.

INTERROGATORIES
All responses hereto are subject to, and ,vithout waiver, of the General Objections which
apply to each ,vithout repetition:

INtERROGATORY NO. 1: Identify by name, address, telephone number and present

employer each and every person Defendant Martin beteves ms knowledge of any facts relevant to
Defendant's Martin's claims in this action. For each such individual ilentified, describe what
knowledge you believe said individual has.
RESPONSE: I am not aware of any other persons ,vith discoverable knowledge outside
of those who have been identified through the initial disclosures in this matter.

INTERROGATORYNO.2: Identify aU documents which in any way support, pertain to, or

relate to the subject matter of this lawsuit or the Defendant Martin's claims against Defendant
Barnett.
RESPONSE: Any and aU documents identified through the initial disclosures in this matter

Case 3:14-cv-00736-HTW-LRA Document 54-5 Filed 04/29/15 Page 3 of 8

may be support, pertain to, or relate to the subject matter of the lawsuit and the claims against
Defendant Barnett. Another document may include a copy of the marriage license between
Precious Martin and Crystal Wise.

INTERROGATORYNO.3: Hentify each person expected to be called as a witness at trial.

RESPONSE: I have not decided who will be caUed as a witness at the trial of this matter;
however, I reserve the right to call as a witness anyone identified through discovery or the initial
disclosures in this matter.

INTERROGATORY NO.4: Identify aU people you have discussed this liigation with and
dentify those from whom you have obtained a written or recorded statement regarding this
litigation.
RESPONSE: None.

INTERROGATORY NO.5: Please explain in detail each and every fact or event of which
Defendant Martin i; aware which support her allegation that Defendant Barnett seduced Precious
Martin.

RESPONSE: Objection. In addition to the general objections stated above, this

interrogatory is overly broad and unduly burdensome. Without waiving this objection, Defendant
Barnett became the bookkeeper for the law firm, Precious T. Martin & Associates, PLLC.
Defendant Barnett became directly privy to the sums of money being earned by the Martin
household and deliberately sought to enter a sexual relationship with Precious Martin to be granted
access and control of said monies.

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:
(n)
The name of each person making the statement;
(b)
The date of the statement;
(c)
The name, employer, occupation, hst known address, and telephone
number of the person taking the statement;
(d)
The name and hst known address and telephone number of the person
now in possession of the original statement or a copy of same.
RESPONSE: None.

INTERROGATORY NO.7: Did your attorney or anyone acting on your behalf conduct an
investigation concerning the subject inci:lents regarding Defendant Barnett? If so, pbse state the
name, address, and taphone number of the person now having custody of each written report
made concerning each investigation.
RESPONSE: No.

INTERROGATORY NO.8: Please i:lentify all persons whom Defendant Martin knows had a
sexual rehtionship with Precious Martin in the past ten (10) years.

Case 3:14-cv-00736-HTW-LRA Document 54-5 Filed 04/29/15 Page 4 of 8

RESPONSE: Objection. In addition to the general objections stated above, this

interrogatory is overly broad and outside the scope of discovery as contemplated by the Fed. R. Civ.
Proc.
INTERROGATORY NO.9: Please ilentify all

se~-ually

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 ilentify
whom he contracted the sexually transmitted disease if known.

RESPONSE: Objection.

In addition to the general objections stated above, this

interrogatory exceeds the scope of discovery as contemplated by the Fed. R. Civ. Proc.

INTERROGATORY NO. 10: Pease identify all life insurance policies that Precious l-.Iartin 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.

RESPONSE: Objection.

In addition to the general objections stated above, this

interrogatory exceeds the scope of discovery as contemplated by the Fed. R. Civ. Proc.

INTERROGATORY NO. 11 Hentify by name, address, and telephone number (lIlcltxling area
code) all hospitak, medical doctors, psychiatrists, psychologists, counselors and other lredi:al
andlor mental healthcare personnel you have contacted, visited, or received treatment in the last
ten (10) years.

RESPONSE: Objection.

In addition to the general objections stated above, this

interrogatory exceeds the scope of discovery as contemplated by the Fed. R. Civ. Proc.

REQUESTS FOR PRODUCTION OF DOCUMENTS

REQUEST NO.1 Please produce all documents identified in response to the foregoing
in terrogatories.
RESPONSE: There are no documents responsive to this request.
REOUEST NO.2: Please produce copies of any recordings, audio-tapes, email or videotape
that ~fendant Martin has in rer possession involving the Defendant Barnett.
RESPONSE: I currendy have no documents responsive to this request.
REQUEST NO.3: Please produce documentation that justifies your claim that Defendant
Barnett was [Dt enrided to the proceeds of the insurance policy in question.
RESPONSE: Please see the copy of the Marriage License between Precious Martin and
Crystal Wise, included here\vith.

Case 3:14-cv-00736-HTW-LRA Document 54-5 Filed 04/29/15 Page 5 of 8

REQUEST NO.4: Prase produce all documents rebted to life insurance policies that
Precious Martin had at the time of his death.

RESPONSE: Objection. In addition to the general objections stated above, this request is
overly broad and exceeds the scope of discovery as contemplated by the Fed. R. Civ. Proc. as it not
reasonably calculated to lead to the discovery of admissible evidence at the trial of this matter.
REQUEST NO.5: Please produce all documents relating to the estate of Precious Martin.
RESPONSE: Objection. In addition to the general objections stated above, this request is
overly broad and exceeds the scope of discovery as contemplated by the Fed. R. Civ. Proc. as it is
not reasonably calculated to lead to the discovery of admissible evidence at the trial of this matter.

REQUEST NO.6: Prase produce all bank statements for IXfendant Martin, Precious
Martin, and any corporation owned by either individual for the past three (3) years.
RESPONSE: Objection. In addition to the general objections stated above, this request is
overly broad, unduly burdensome and exceeds the scope of discovery as contemplated by the Fed.
R. Civ. Proc.

REQUEST NQ. 7: Please execute and return the attached HIPAA release.
RESPONSE: Objection. In addition to the general objections stated above, this request is
irrelevant, overly broad, unduly burdensome and exceeds the scope of discovery as contemplated by
the Fed. R. Civ. Proc.

THIS the 15dl day of April, 2015.

CH C McRAE, MSB #2804

SETH C. LITTLE, MSB #102890
CHRISTOPHER A. BAMBACH, MSB #104838
McRAE LAW FllUvI, PLLC
416 EAST AMITE STREET
JACKSON, MS 39201
Tel.: 601.944.1008
Facsimile: 866.236.7731
Email: chuck@mcraclaw.nct
scth@mcraclaw.nct
christophcr@mcraclaw.nct

Case 3:14-cv-00736-HTW-LRA Document 54-5 Filed 04/29/15 Page 6 of 8

State of ....L.....J..:....c::.;,-=-~>F"-I~\_ _
County of--l,...;....:I..l-~:..a!io.

PERSONAILY CAME AND APPEARED before me, the undersigned authority in and for
the jurisdiction aforesaid, the within named CRYSTAL WISE MARTIN, who after being by me first
duly sworn states on oath that the matters and facts contained in the above and foregoing Responses
to Defendant's First Set of Discovery are true and correct as therein tated.

SWORN

TO.j\NlltW~~CRIBEDBefore me, this

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2016 ~ .-

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MY COMMISSION E.."XPIRES:

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Of_Bv~F-/(";"""":\"';;"'"\~_ _- ' , 2015.

Case 3:14-cv-00736-HTW-LRA Document 54-5 Filed 04/29/15 Page 7 of 8

CERTIFICATE OF SERVICE
I, Chuck r-.'fcRae, do hereby certify that I have sent a copy of the foregoing and filed a Notice
of Service regarding the delivery of the same with the Court's electronic filing system which
automatically sends notification to all attorneys of record.
This the 15m day of April, 2015.

CHUCK McRAE, MSB #2804

CHUCK McRAE, MSB #2804
SETH C. UTILE, MSB #102890
CHRISTOPHER A. BMffiACH, MSB #104838
McRAE LAW FIlUvl, PLLC
416 EAST AMITE STREET
JACKSON, MS 39201
Tel.: 601.944.1008
Facsimile: 866.236.7731
Email: chuck@mcraclaw.nct
scth@mcraclaw.nct
christophcr@mcraclaw.nct

Case 3:14-cv-00736-HTW-LRA Document 54-5 Filed 04/29/15 Page 8 of 8

STATE OF MISSISSIPPI

MARRIAGE LICENSE
COUNTY OF

Hinds
To any Judge, Minister. Justice or any olher Person Lawfully authorized 10 celebrate Ihe Rites of Macrimony:

YOU ARE HEREBY LICENSED TO CELEBRATE THE

RITES OF MATRIMONY
BE'TWEEN

---:P,-",R=EC=I:.;:;O=US~_-,-TY.....::R=O=NN=E=---_.....:H=A:.:.:.RT.:..:I=N

Mr.
Miss

CRYSTAL

DIANE

and

WISE

and for so doing this shall be your warrant.

Given under my hand and official seal, this the

day of .....:..A~P..:.:R:.::;I-=L

17TH

in the year of our Lord

1998

BARBARA DUNN. Circuit Clerk.

SEAL
By

LORETTA WELLS

D.C.

Martin 001

The State of Mississippi, Hinds County

By Virtue of a License
from the Clerk of the Circuit Court of said County of Hinds, I have this day celebrated the
Rites of Matrimony between
Mr. _-,-P.:.:.:RE=C=I=OU:.;:;S,--_T:..:Y...:.:R=ON=N=E_ _...:.:H:.:::AR~T..:.I:.:..N
Miss _....;;;;C.;.;.RY"""S;..:,.T:..:.;AL=--_-=DI=A=N=E
Given under my hand, this the

and

W;;.:I:.;:;S. :,E
23RD

day of.....:.:H::.,:A.:,.Y

A. D.

_-=.J=.:ER~R:.:..Y_Y:..::O:.::U.:.:.;NG=--

I, Barbara Dunn, Clerk of the Circuit Court in and

for the said State and County do hereby certify thet

.....:(Seal)

Given under n:!Y hand and the Beel of the seal of the Circuit Court
JACKSON
this the
9TH day of FEBRUARY
at

I; J '

the above and foregoing is a true and correct copy

,h

ofthe original MARRIAGE LICENSE and the same Is

of record in this office in Book No.
at page _----=9;...

209

1998

By

-"

~ ,...-:r"

2011

BARBARA DUNN. Circuit Clerk

//J."

D. C.