IN THE CIRCUIT COURT OF PULASKI COUNTY, ARKANSAS
`DOMESTIC RELATIONS - 4™ DIVISION
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`JOHN CHARLES “JC” CONKLIN PLAINTIFF
`V. CASE NO. 60DR-25-1878
`JENNIFER CONKLIN DEFENDANT
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`RESPONSE TO PLAINTIFF’S MOTION TO COMPEL AND INCORPORATED BRIEF
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`COMES NOW the Defendant, Jennifer Conklin, by and through her attorneys, LaCERRA,
`DICKSON, HOOVER, & ROGERS, PLLC, and for her Response to Plaintiff’s Motion to Compel
`and Incorporated Brief. states as follows:
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`1. That the docket and pleadings speak for themselves in this matter; therefore, a
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`response is not required to paragraph one (1) of the Plaintiff’s Motion.
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`2. The Defendant admits the allegations contained in paragraph two (2) of the
`Plaintiff's Motion.
`3. The Defendant denies the allegations as stated in paragraph three (3) of the
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`Plaintiff’s Motion. Stating affirmatively, the Defendant provided Responses to Plaintiff’s Set of
`Interrogatories and Requests for Production of Documents on August 18, 2025.
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`4. That Arkansas Rule of Civil Procedure 37 speaks for itself; therefore, a response is
`not required to paragraph four (4) of the Plaintiff’s Motion.
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`5. The Defendant admits that an email correspondence was sent by opposing counsel
`on Friday, August 15, 2025, but denies that her responses were tendered at 4:02 p.m. The
`Defendant is without sufficient information to admit or deny the remaining allegations in
`paragraph five (5) of the Plaintiff’s Motion. Inasmuch a response is required, the Defendant denies
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`the same. Stating affirmatively, please see attached Exhibit A.
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`Page 1 of 3
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`6. The Defendant admits she objected to Request for Production No. 11, but she is
`without sufficient information to admit or deny the remaining allegations in paragraph six (6) of
`the Plaintiff’s Motion. Inasmuch a response is required, the Defendant denies the same.
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`7. That Arkansas Rules of Civil Procedure 33 and 34 speak for themselves; therefore,
`a response is not required to paragraph seven (7) of the Plaintiff’s Motion. Inasmuch a response is
`required, the Defendant denies the same.
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`8. The Defendant admits the allegations contained in paragraph eight (8) of the
`Plaintiff’s Motion.
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`0. The Defendant denies the allegations contained in paragraph nine (9) of the
`Plaintiff’s Motion.
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`10. Arkansas Rule of Civil Procedure 33 speaks for itself; therefore, a response is
`required to paragraph 10 of the Plaintiff’s Motion. Inasmuch a response is required, the Defendant
`denies the same.
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`11. The Defendant objects to the requested relief in paragraph eleven (11) of the
`Plaintiff’s Motion. Stating affirmatively, the Counsel for the Plaintiff inquired about the
`information sought in Request for Production No. 11 at the temporary hearing in this matter on
`August 19, 2025.
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`12. That Arkansas Rule of Civil Procedure 37 speaks for itself, but the Defendant
`denies the remaining allegations contained in paragraph twelve (12) of the Plaintiff’s Motion.
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`13. The Defendant denies the allegations contained in paragraph thirteen (13) of the
`Plaintiff’s Motion. Stating affirmatively, the Plaintiff did not send any correspondence after the
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`Defendant sent her Responses to Plaintiff’s Set of Interrogatories and Requests for Production of
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`Page 2 of 3
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`Documents regarding any alleged deficiencies. The Defendant cannot be expected to cure any
`alleged deficiencies or alleged insufficient responses if she is not made aware of them.
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`14. All allegations not specifically admitted are herein denied including those requests
`for relief contained in the Plaintiff’s WHEREFORE paragraph.
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`15. That the Defendant reserves the right to amend and plead further.
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`WHEREFORE, the Defendant prays that the Plaintiff’s Motion be denied; for attorneys’
`fees and costs; and for any and all other relief to which the Defendant may be entitled.
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`Respectfully submitted,
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`By: /s/ g race %%@%X 2
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`Traci LaCerra #97019
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`LACERRA, DICKSON, HOOVER
`& ROGERS, PLLC
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`212 Center Street, Second Floor
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`Little Rock, Arkansas 72201
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`(501) 476-3064
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`tlacerra@ldhrlaw.com
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`CERTIFICATE OF SERVICE
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`I, Traci LaCerra, do hereby certify that a copy of the foregoing pleading has been sent via
`electronic filing to the following:
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`Mr. Bart Calhoun
`bart@mcdanielwolff.com
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`/s/ %fié % %ému
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`Traci LaCerra
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`Page 3 of 3
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`From: Amanda Willi
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`To: Bart Calhoun
`Cc: Beth_Clements; Lauren McCauley; Traci Lacerra; Chandler Sullivan
`Subject: RE: 60DR-25-1878 Conklin v. Conklin
`Date: Monday, August 18, 2025 4:00:28 PM
`Attachments: 25.8.18 - Responses to
`image001.png
`image002.png
`Bart-
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`Please see attached our client’s Responses to Plaintiff’s Set of Interrogatories and Requests for
`Production of Documents.
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`Thanks,
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`Amanda N. Williamson
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`Associate Attorney
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`LaCerra, Dickson, Hoover, & Rogers, PLLC
`The Centre Place Building
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`212 Center Street, 2" Floor
`Little Rock, Arkansas 72201
`Phone: (501) 456-7010
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`Fax: (501) 246-5155
`awilliamson@Idhrlaw.com
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`Link to Schedule an Appointment: https://calend] illi -idhriaw
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`**When responding, please hit reply all
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`The information contained in this e-mail is from the law firm of LaCerra, Dickson, Hoover & Rogers, PLLC., and may
`be privileged, confidential and protected from disclosure. If you are not the intended recipient, any further
`disclosure or use, dissemination, distribution, or copying of this message or any attachment is strictly prohibited. If
`you think that you have received this e-mail message in error, please delete the e-mail and either e-mail the sender
`at the above address or notify us at our telephone number, 501-476-3064.
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`EXHIBIT
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`tabbies®
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