Fill and Sign the Morton Law Firm the Mississippi Probate in a Nutshell Form

IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI , a Mississippi CorporationVS.THE KNOWN AND UNKNOWN HEIRS,SUCCESSORS AND ASSIGNS OF: , DECEASED, A/K/A , A/K/A , THE KNOWN AND UNKNOWN HEIRS,SUCCESSORS AND ASSIGNS OF , DECEASED;THE KNOWN AND UNKNOWN HEIRS,SUCCESSORS AND ASSIGNS OF THE KNOWN AND UNKNOWN HEIRS,SUCCESSORS AND ASSIGNS OF , , , , AND PLAINTIFF'S FIRST SET OF INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS,AND REQUEST FOR ADMISSIONS PROPOUNDED UPON COMES NOW, , by and through its attorney and propounds the following Interrogatories to the Defendant, , to be answered under oath within thirty (30) days.NOTE A: When used in these Interrogatories the term "Defendant" or any synonym thereof, is intended to and shall embrace and include, in addition to said Defendant, all agents, servants, representatives, private investigators, and others, who are in a position or may have obtained information for or on behalf of the Defendant.NOTE B: Pursuant to Mississippi Rules of Civil Procedure these Interrogatories shall be deemed continuing so as to require supplemental answers if you, your attorneys, or other representative, obtain further information. If additional information is acquired, you are under a duty to supplement said answers. DEFINITIONS The following definitions apply throughout the present set of Interrogatories and shall be adopted by Defendant and responded thereto. A."Complaint" refers to the Complaint filed by Plaintiff in the present action and any amendment thereto.B."Answer" shall mean the Answer of the Defendant in the present action and any amendment thereto.C."Person" shall mean any natural person or entity, whether business entity, corporation, association, firm, partnership or otherwise, governmental entity, other legal entity or any agency, bureau, committee, department, division, subdivision or subsidiary thereof.D."Representative" shall mean any officer, director, agent, employee, attorney, servant or other person acting for or on behalf of the person referred to in the Interrogatory or definition or of the person's affiliate.E."Document" shall mean the original (or copy if the original if not available) and each non-identical copy (whether non-identical because of alternations, attachments, blanks, comments, notes, underlining or otherwise) or any writing or record, however, described, whether account, agreement, amendment, article, authorization, bank advance or similar notice for transfer, bank statement, bill of lading, blueprint, book, chart, check, contract, correspondence, deposit slip, diary, drawing, entry, estimate or cost to complete estimate, film, tape, financial statement, graph, instruction, internal document, invoice, journal, ledger or subsidiary ledger, letter, memorandum, minutes, notes work papers, studies, notebook, plan, photocopy, photograph, projection, publication, purchase order, recording report, schedule scrapbook, sketch, specification, speech, tape, telegram, telex, transcript, voucher or otherwise, and all retrievable data (whether incarded, taped or coded electronically, electro-magnetically or otherwise) in the possession, custody or control of Defendant, or known to Defendant wherever the document is located, however produced or reproduced, whether draft or final version.F."Communication" or "statement" means any transfer of information by oral statement, document, device or otherwise.G."You" or "yours" means the Defendant and any applicable representatives, directors, officers, employees, engineers or servants, regardless of whether such individuals are representatives, etc. of you.H."Relating" to includes, but without limitation, mentioning, discussing, commenting on, referring to, pertaining to, alluding to, relevant to, or in any way touching upon, or connecting with. I."Identify" when used in reference to: 1.A natural person shall mean to state the person's full name, present or last known address and telephone number; 2.A business or governmental entity, not a natural person, shall mean to state the entity's full name, principal activities and type of entity (agency, association, corporation, partnership, department, division, etc.)3.A document, shall mean to state the document's description, title, date, subject matter, author, and the name and address of the person who has custody of such document.INTERROGATORY NUMBER ONE: In numbered paragraph of your Answer, you admitted all deraignments in numbered paragraph of the Complaint, except item numbered . Set out in detail what you know and what you have heard, distinguishing between the two, regarding any usage of the land that is the subject of this lawsuit by ,