IN THE SUPERIOR COURT OF COWETA COUNTY
STATE OF GEORGIA
L-STRATEGIES, LLC,
Plaintiff,
vs.
EDWARD CONZ, JR,
Defendant.
CIVIL ACTION NUMBER: SUV2024000334
ORDER GRANTING PETITIONER’S MOTION TO COMPEL
The above matter is before the Court on Petitioner’s Motion to Compel, which was filed on January 8, 2025, along with supporting documents. Counsel for Petitioner sent correspondence pursuant to Unif. Sup. Ct. R. 6.4(B) and Respondent has thus far refused to respond to the discovery requests. Additionally, Respondent filed his responsive objection to Petitioner’s motion. Having considered all of the filings and evidence presented, the Court hereby FINDS and ORDERS as follows:
Petitioner’s Motion to Compel is GRANTED. At the time Petitioner’s Motion was filed, Respondent had failed to fully and adequately respond to discovery and since then no supplementation has been made. The Court finds that the Petitioner served Respondent with the First and Continuing Interrogatories, First Request for Admissions, and First and Continuing Request for Production of Documents and Notice to Produce on or around July 26, 2024. The Respondent failed to respond to either request within the required thirty (30) days after service, and therefore his ability to object has been waived pursuant to Georgia law. After attempting to resolve the discovery dispute according to Uniform Superior Court Rule 6.4(b) the Petitioner sent a letter seeking responses on August 9, 2024. The Respondent responded to the Rule 6.4(b) letter via email, but did not deliver any additional evidence other than those contained in the limited responses on September 30, 2024. The Petitioner attempted to gain compliance by filing his Motion to Compel on January 8, 2025. Respondent responded to the motion with objections, and no further discoverable evidence was offered or delivered. Respondent failed to give timely objections to discovery as set forth in O.C.G.A. §§9-11-33, 9-11-34, 9-11-36, and although his right to object to discovery was waived due to untimely responses, Respondent still refused to deliver any documents, complete responses, or supplementation to Plaintiff in bad faith.
IT IS HEREBY ORDERED
Respondent must comply with his discovery obligations and provide Petitioner with full, complete, sufficient, and verified responses, without objection, to:
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First and Continuing Interrogatories
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First Request for Admissions
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First and Continuing Request for Production of Documents and Notice to Produce
...within sixty (60) days, but in no case later than 5:00 P.M. EST on June 30, 2025.
Specific responses and evidence required:
Request for Production of Documents and Notice to Produce
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RPD #3: Copies of any and all communications—including emails, texts, instant messages, social media comments, and call/video transcripts—between Respondent and:
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Jared B. Craig, Esq.
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Patrick Collis
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Margaret Ackiss
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Vlad Lemets
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XXXXXXXXXX (Redacted)
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XXXXXXXXXX (Redacted)
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XXXXXXXXXX (Redacted)
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XXXXXXXXXX (Redacted)
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XXXXXXXXXX (Redacted)
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XXXXXXXXXX (Redacted)
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XXXXXXXXXX (Redacted)
(From January 1, 2022 to June 30, 2025)
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RPD #4: All phone records for any telephone in your possession or used by you from Jan 1, 2022 to June 30, 2025
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RPD #5: All reports from any and all third parties in your possession concerning your relationship with L-Strategies, LLC (dba Veterans for America First/fka Veterans for Trump, Jared B. Craig, Patrick Collis, Vlad Lemets, Margaret Ackiss, and XXXXXXXXXX (Redacted) since January 1, 2022 to present)
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RPD #9: All documents related to the creation of the website www.VFAFNC.org including communications with web designers, domain registration, etc.
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RPD #10: Copies of all social media posts from all accounts/platforms where you are authorized to post
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RPD #11: Copies of any and all press releases drafted or published by you concerning Petitioner from Jan 1, 2022 to present
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RPD #14: Copies of all contracts entered on behalf of the North Carolina VFAF State Chapter since Nov 15, 2023 to present
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RPD #21: All documents related to acquiring your prior and/or current legal representation, including agreements, invoices, and payment sources
Petitioner’s First Interrogatories to Respondent
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Int #2: Full list of individuals with knowledge of the case, including scope of knowledge
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Int #4: Identify all physical, documentary, and tangible evidence
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Int #6: List all communications with Petitioner about negotiations and purchase of the NC VFAF Chapter prior to Nov 15, 2023
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Int #7: List each person who assisted in cloning www.VFAFNC.org and placing unauthorized site on non-compliant server
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Int #8: State reasons for creating the .com site after purchasing the .org site
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Int #9: List all members of current NC VFAF organization
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Int #11: Explain your relationship with XXXXXXXXXX (Redacted)
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Int #12: Explain your relationship with Patrick Collis
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Int #13: Explain your relationship with Vlad Lemets
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Int #14: Explain your relationship with XXXXXXXXXX (Redacted)
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Int #15: Explain your relationship with XXXXXXXXXX (Redacted)
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Int #17: List all social media accounts you control, with usernames and passwords
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Int #18: List all press releases drafted or published from Nov 15, 2023 to present
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Int #19: List all media contacts made on behalf of NC VFAF from Nov 15, 2023 to present
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Int #21: List all income sources since Nov 15, 2023 including amounts and contact info
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Int #24: List all businesses where you had ownership or management interest since Nov 15, 2023
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Int #25: List all individuals/entities who paid personal, business, legal, or medical expenses on your behalf since Nov 15, 2023
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Int #30: List all legal proceedings (civil and criminal) you’ve been a party to in the past 10 years
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Int #32: Identify who paid your legal fees in this action
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Int #35: Explain your relationship with XXXXXXXXXX (Redacted)
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Int #36: Explain your relationship with Margaret Ackiss
NOTICE FOR COMPLIANCE
If Respondent fails to strictly comply with this Order by June 30, 2025 at 5:00 PM, he shall be found in willful contempt and subject to:
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Reimbursement of litigation expenses
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Attorney fees
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Monetary sanctions
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Striking of responsive pleadings
Petitioner also sought attorney’s fees and litigation expenses of $2,200.00 under O.C.G.A. § 9-11-37(a)(4)(A). The Court reserves this issue until the final order in the case.
SO ORDERED this the ___ day of ____________, 2025.
[Signed]
Judge W. Travis Sakrison
Superior Court of Coweta County
Prepared by:
/s/ Matthew Hammett, Esq.
Matthew Hammett, Esq.
Counsel for Petitioner
20 Baker Road, Suite 5
Newnan, Georgia 30265
Hammett.attorney.law@gmail.com
CERTIFICATE OF SERVICE
This certifies that a copy of this Order was served via Statutory Electronic Service to:
Edward F. Conz, Jr.
c/o James Hawkins, Esq.
Email: jhawkins@ichterdavis.com
Respectfully submitted this ___ day of __________, 2025.
/s/ Matthew Hammett, Esq.
Matthew Hammett, Esq.
Counsel for Petitioner
