Respondent Response to Request for Production of Documents

• •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