EBERHARDT, Judge.
1-2. Headnote 1, dealing with the general grounds, and Headnote 2, concerning special ground 4, need no elaboration.
3. Plaintiff served defendant with interrogatories under Code Ann. § 38-2109 (b) seeking certain information and the discovery of written statements which the defendant may have obtained from members of the train crew who were on the train involved in the collision. Defendant filed objections to the interrogatories...
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