Case No. 19-CVS-1140

This page is divided into sections.  The first section will contain First Set of Interrogatories, the second section will contain the production of supporting documents.  The third section Requests to Admit has been signed and mailed and will not be included here.

All documents are available and linkable for downloading purposes.

First Set of Interrogatories

The first Set of Interrogatories was written in a word document  called:  Case CVS-1140 Clontz vs Merical.


Production of Supporting Documents

PM POA Governing Documents:
PM Employee Governing and Reference Documents
PM Board of Directors Instructional Guidelines and Forms
PM Golf Employee Job Descriptions

CVS-1140 Answers:

Time Frame:  November 2017 – May 2019   Reason:  This is the time period Wanda Merical was Pine Mountain POA, Inc.’s President of the Board of Directors.  All other time frames within the request (July 1, 2016 to present) cannot be fully answered nor does the scope of search or investigation extend within the desired time due to not being privy to receive and/or create any documentation (as defined within the request), was not part of any discussion(s) or hearsays that has been detailed, remembered or repeatable with any accuracy for this case.

Special Note:  July 15, 2017, Pine Mountain Members voted to completely remove all current board members and vote in an Interim Board for a period of 1-year.  18 September 2017 a court judge ruled the replacement of the previous board, removing the Interim Board.  The Interim Board was officially placed back in place 4 November 2017.  No official actions were conducted only discussions on how to proceed as a Board by the Interim Board between July 15, 2017 and 18 September 2017, therefore all contents of this document do not include those dates.