Respondent Response to Request for Production of Documents

1• 234567891011121314• 151617181920212223242526• 2728• •Production and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to responses served on August 22, 011, June 27,2011, May 7, 2010, July 15, 2009 and August 18, 2008. Respondent has made adiligent 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, Respondentshall produce all documents requested in this paragraph that are in his possession,custody, and control, which are described below.A. Earnings Statements from CSldentity Corporation for October 1, 2011through November 15, 2011B. Profit and Loss Statement — YTD for MJC Enterprises for January 1, 2011through November 22, 2011RESPONSE TO REQUEST NO. 34: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 responds as follows: Respondent is unable to comply with thisrequest because to his knowledge the documents requested do not exist.RESPONSE TO REQUEST NO. 35:Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forProduction and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to responses served on August 22, 011, June 27,2011, May 7, 2010, July 15, 2009 and August 18, 2008. Respondent has made adiligent 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: See response to request number 33 above.RESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX14