Respondent Response to Request for Production of Documents

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1• 2345678910111213Respondent also objects to this request as being vague and ambiguous. Respondenthas made a diligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentresponds as follows: Respondent is unable to comply with this request because to hisknowledge the documents requested do not exist.RESPONSE TO REQUEST NO. 29:Respondent objects to this request because it is not reasonably calculated tolead to the discovery of information relevant to the subject matter of this action nor tothe discovery of admissible evidence, and is therefore burdensome and oppressive.Respondent also objects to this request as being vague and ambiguous. Respondenthas made a diligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right to•14151617181920212223242526amend this Response. Without waiving his objections to this request, Respondentresponds as follows: Respondent is unable to comply with this request because to hisknowledge the documents requested do not exist.RESPONSE TO REQUEST NO. 30:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Without waiving his objections to thisrequest, Respondent shall produce all documents requested in this paragraph that arein his possession, custody, and control, which are described below.A. Bank of America statements for account number 09073-41183 for theperiod of June 14, 2011 through October 12, 2011B. HSBC Premier statements for account number 843-00644-7 for the periodof August 24, 2011 through October 26, 2011• 2728C. Union Bank statements for account number 0801236977 for the period ofJune 7, 2011 through November 4, 2011RESPONDENTS RESPONSE TO PETITIONERS REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX12
• •1• 234567891011121314• 151617181920212223242526• 2728D. Union Bank statements for account number 0800043204 for the period ofJuly 1, 2011 through October 31, 2011RESPONSE TO REQUEST NO. 31:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Without waiving his objections to thisrequest, Respondent shall produce all documents requested in this paragraph that arein his possession, custody, and control, which are described below.A. Citi Platinum Select statements for account number ending 1758 for theperiod of June 2, 2011 to October 4, 2011B. Citi American Airline Advantage statements for account number ending2596 for the period of June 28, 2011 to October 28, 2011C. American Express TrueEarnings Business Card statements for accountnumber ending 7-51003 for the period of June 18, 2011 to October 21, 2011D. See response 1A for statements for Capital One account number ending -0631 dated May 17, 2011 through October 16, 2011.E. See response 1B for statements for Discover account number ending -2077dated July 3, 2010 through June 4, 2011.RESPONSE TO REQUEST NO. 32:Respondent objects to this request as being vague and ambiguous.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested is not in his possession if it exists at all.RESPONSE TO REQUEST NO. 33:Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forRESPONDENTS RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX13
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Page 24 and 25: VERIFICATIONI, MICHAEL J. CALDWELL,

Respondent Response to Request for Production of Documents

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