DJAMAF1 & Associates LLP
Discord: DJAMAF2010
August 2, 2025
To:
NICKLAUS_S, Partner
NOTSFEELINGS, Partner
520 Third Street, Suite 330 • Mersea, MF 10007
250 Farley Street • Palmer, RW 90025
RE: Response to Discovery Requests
Case: RSC-CV-2876 | RichardLennox v. Andrew_DeRosa
To Whom It May Concern:
Pursuant to the Ridgeway Rules of Civil Procedure, Defendant Andrew_DeRosa, by and
through undersigned counsel, hereby responds to Plaintiff’s Discovery Requests dated July 26,
2025, as follows:
I. GENERAL OBJECTIONS
Defendant objects to each and every request to the extent it seeks information protected by
attorney-client privilege, work product doctrine, or any other applicable privilege or protection.
These responses are provided without waiver of such protections and are subject to
supplementation as required by law.
II. RESPONSES TO REQUESTS FOR PRODUCTION
RFP 1:
https://medal.tv/games/roblox/clips/kGy2E8KlDBkC_bdBy?invite=cr-MSxlRW4
RFP 2:
Partial Objection - Relevance, this request is asking for all communications, some of which may
not be directly relevant to this case. Attached is any relevant communications in our possession
at this time.
https://gyazo.com/5d9b833463d51d7f78e1678d5def8019
RFP 3:
https://medal.tv/games/roblox/clips/kGy2E8KlDBkC_bdBy?invite=cr-MSxlRW4
RFP 4:
No witness statements at this time. One witness, SoupRokossovsky was contacted but to no
avail.
RFP 5:
Objection as premature. Defendant has not retained any expert witnesses at this time.
Defendant will produce expert reports in accordance with the applicable discovery schedule if
and when they are prepared.
RFP 6:
Limited objection. Defendant objects to the extent the request is vague, overly broad, or seeks
irrelevant communications. Defendant will produce relevant public communications directly
related to the incident.
https://gyazo.com/5d9b833463d51d7f78e1678d5def8019
RFP 7/7a:
Objection - Relevance, Andrew_DeRosa owning a firearms license is irrelevant to the claims
against him. Also calls for a legal conclusion and is an improper request as it requires a party to
admit to a legal violation.
III. RESPONSES TO REQUESTS FOR ADMISSION
RFA 1:
Admit
RFA 2:
Admit
RFA 3:
Defendant objects to this request on the grounds that it is vague and ambiguous as it fails to
specify when, how, or under what circumstances the alleged possession of a firearm occurred.
Without such contextual details, the Defendant cannot reasonably admit or deny the request.
RFA 4:
Objection - calls for a legal conclusion. Improper request as it requires a party to admit to a legal
violation. Also objects on the grounds that the request is for information irrelevant to the claims
made against the defendant.
RFA 5:
Defendant objects to this request as vague and ambiguous. The request fails to specify the
time, location, or circumstances under which the alleged discharge of a firearm is claimed to
have occurred, making it impossible to provide a clear and accurate admission or denial.
RFA 6:
Objection - calls for a legal conclusion and assumes a fact in controversy, specifically, that
RichardLennox was shot and that Defendant was the actor. Also vague as to time, location, and
means.
RFA 7:
Objection - compound, assumes multiple events without foundation. Vague and speculative.
Calls for speculation and a legal conclusion.
RFA 8:
Objection - Vague and ambiguous as to “involved.” Assumes a legal conclusion and is
argumentative in form.
RFA 9:
Objection - Calls for a legal conclusion. This is not a proper request for admission of fact, but
rather a request to admit liability — which is a matter for the trier of fact.
RFA 10:
Objection - Duplicative of Request No. 1
RFA 11:
Defendant objects to this request on the grounds that it is vague and not relevant to any claim or
defense in this matter.
Subject to and without waiving the objection, Defendant admits to stating, “you ain’t getting shit
bud,” in the #general-chatroom channel of the State of Ridgeway Discord server, and that it was
directed at the plaintiff.
IV. RESPONSES TO INTERROGATORIES
INT 1:
I am unemployed.
INT 2:
N/A - Andrew_DeRosa is unemployed.
INT 3:
Objection - Defendant objects to this interrogatory as overbroad and unduly burdensome to the
extent that it seeks identification of “all” persons with knowledge of the events, as it is not
feasible to identify every such individual without the benefit of further discovery. The request is
also vague as to what constitutes “knowledge” of the events. Subject to and without waiving
these objections, Defendant identifies the following individuals currently known to have relevant
knowledge:
AfricaFarmer – driver of the vehicle involved and witness to key aspects of the incident.
RichardLennox – Plaintiff, directly involved in the incident and alleged to have interacted with
Defendant during and after.
SoupRokossovsky – present during the relevant timeframe and may possess material
knowledge regarding the events or surrounding context.
Defendant reserves the right to amend or supplement this response as discovery proceeds.
INT 4:
Objection - Defendant objects on the ground that this request is compound, overly broad, and
vague as to the scope of "events" and "after."
INT 5:
Objection - Defendant objects on the basis that this request is overbroad and vague as to time
frame and scope. Subject to and without waiving the objection, responsive communications
already produced or identified in discovery may apply.
INT 6:
Objection - Defendant objects on the grounds that this request prematurely seeks trial strategy
and attorney work-product. Defendant will comply with disclosure requirements as dictated by
the pretrial scheduling order or applicable procedural rules. Subject to and without waiving the
objection, witnesses already produced or identified in discovery may apply.
INT 7:
Objection - Defendant objects on the ground that this request seeks premature disclosure of trial
exhibits and is more appropriately addressed in pretrial disclosures. Subject to and without
waiving this objection, evidence already identified in discovery may be used.
INT 8:
Objection - Defendant objects to this request as it improperly calls for a legal conclusion and the
premature disclosure of trial theory and defense strategy. Defendant will assert legal defenses in
the appropriate filings and proceedings.
INT 9:
Objection - Defendant objects to this interrogatory on the grounds that it calls for a legal
conclusion, and infringes upon Defendant’s Fifth Amendment right against self-incrimination, to
the extent applicable in this context. Furthermore, the interrogatory is compound,
argumentative, and vague as to the term “uniformed police officer,” including no clear
identification of the individual in question, time, or circumstances. For these reasons, Defendant
declines to respond at this time.
INT 10:
Objection - Defendant objects to this request as vague, overbroad, and lacking temporal
specificity. It does not specify the time or incident referenced. Subject to and without waiving the
objection, Defendant reserves the right to respond after clarification.
INT 11:
Simply because I wished to return to the car, and for the purpose of my safety.
Respectfully submitted,
DJAMAF1, Esq.
Managing Partner
DJAMAF1 & Associates LLP
Counsel for Defendant Andrew_DeRosa
