IN THE CIRCUIT COURT OF THE STATE OF OREGON

FOR THE COUNTY OF MULTNOMAH

CATHERINE LYNNE CARTER, Petitioner
v
RORY GREY BOWMAN, Resondent

Case No. 060303051
RESPONDENT’S REQUESTS FOR ADMISSION

FAILURE TO SERVE A WRITTEN ANSWER OR OBJECTION WITHIN THE TIME ALLOWED BY ORCP 45 B WILL RESULT IN ADMISSION OF THE FOLLOWING REQUESTS.

Respondent Rory Grey Bowman, through counsel, respectfully requests that petitioner admit the truth of the statements set forth below.

1

Between April 21, 2004, and April 21, 2006, respondent did not come into the visual or physical presence of petitioner except at the trial of this matter on April 21, 2006.

NOT WITHIN PETITIONER’S KNOWLEDGE

2

Between April 22, 2006, and May 22, 2009, respondent did not come into the visual or physical presence of petitioner.

DENY

3

Between April 21, 2004, and April 21, 2006, respondent did not follow petitioner.

NOT TO PETITIONER’S KNOWLEDGE

4

Between April 22, 2006, and May 22, 2009, respondent did not follow petitioner.

NOT TO PETITIONER’S KNOWLEDGE

5

Between April 21, 2004, and April 21, 2006, respondent did not wait outside petitioner’s home, property, place of work, or school.

NOT TO PETITIONER’S KNOWLEDGE

6

Between April 22, 2006, and May 22, 2009, respondent did not wait outside petitioner’s home, property, place of work, or school.

NOT TO PETITIONER’S KNOWLEDGE

7

Between April 21, 2004, and April 21, 2006, respondent did not send or make written or electronic communications in any form to petitioner herself.

ADMIT

8

Between April 22, 2006, and May 22, 2009, respondent did not send or make written or electronic communications in any form to petitioner herself.

ADMIT

9

Between April 21, 2004, and April 21, 2006, respondent did not speak with petitioner by any means other than at the trial of this matter on April 21, 2006.

ADMIT

10

Between April 22, 2006, and May 22, 2009, respondent did not speak with petitioner by any means.

ADMIT

11

Between April 21, 2004, and April 21, 2006, respondent did not make a communication to any person with the intent that it be relayed to petitioner.

DENY

12

Between April 22, 2006, and May 22, 2009, respondent did not make a communication to any person with the intent that it be relayed to petitioner, other than requesting through counsel that petitioner move to vacate the stalking protective order in this case.

DENY

13

Respondent has not been arrested for, nor charged with, a crime against petitioner.

ADMIT

14

Between April 21, 2004, and April 21, 2006, respondent did not commit any crimes against petitioner.

ADMIT

15

Between April 22, 2006, and May 22, 2009, respondent did not commit any crimes against petitioner.

NOT TO PETITIONER’S KNOWLEDGE

16

Between April 21, 2004, and April 21, 2006, respondent did not communicate with any person, other than Kevin Balmer, who has a relationship with petitioner with the intent of affecting that person’s relationship with petitioner.

DENY

17

Between April 22, 2006, and May 22, 2009, respondent did not communicate with any person, other than Kevin Balmer, who has a relationship with petitioner with the intent of affecting that person’s relationship with petitioner.

DENY

18

Kevin Balmer has never told petitioner that respondent’s communications with Balmer in 2006 had any effect on Balmer’s relationship with petitioner.

DENY

19

Kevin Balmer has never told petitioner that, during respondent’s communications with Balmer in 2006, respondent stated any intent to affect Balmer’s relationship with petitioner.

DENY

20

Between April 21, 2004, and April 21, 2006, respondent did not communicate with any business entity with the intent of affecting some right or interest of petitioner.

NOT WITHIN PETITIONER’S KNOWLEDGE

21

Between April 22, 2006, and May 22, 2009, respondent did not communicate with any business entity with the intent of affecting some right or interest of petitioner.

DENY

22

Between April 21, 2004, and April 21, 2006, respondent did not damage petitioner’s home, property, place of work, or school.

NOT WITHIN PETITIONER’S KNOWLEDGE

23

Between April 22, 2006, and May 22, 2009, respondent did not damage petitioner’s home, property, place of work, or school.

NOT WITHIN PETITIONER’S KNOWLEDGE

24

Between April 21, 2004, and April 21, 2006, respondent did not deliver, directly or through a third person, any object to the home, property, place of work, or school of petitioner.

NOT WITHIN PETITIONER’S KNOWLEDGE

25

Between April 22, 2006, and May 22, 2009, respondent did not deliver, directly or through a third person, any object to the home, property, place of work, or school of petitioner.

NOT WITHIN PETITIONER’S KNOWLEDGE

26

Petitioner has never seen respondent injure another person.

ADMIT

27

Petitioner has never seen respondent brandish a weapon or carry a weapon in a hostile manner.

ADMIT

28

Every communication that petitioner’s counsel has received from respondent or respondent’s counsel since April 21, 2006, has concerned requests by respondent to vacate or terminate the stalking protective order in this case.

DENY

29

Petitioner believes that respondent currently resides in Vancouver, Washington.

PETITIONER HAS NO KNOWLEDGE OF RESPONSDENT’S WHEREABOUTS

30

Petitioner has refused to move to vacate the stalking protective order in this case.

ADMIT