Respondent Response to Request for Production of Documents

• •••12345678910111213141516171819202122232425262728requested in this paragraph that are in his possession, custody, and control, which aredescribed below.PayPal Transaction History for January 1, 2008 through November 9, 2011RESPONSE TO REQUEST NO. 7:Respondent objects to this request because it is 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 documents requested do not exist.RESPONSE TO REQUEST NO. 8:Respondent objects to this request as being vague, ambiguous and overlyburdensome.Respondent also objects to this request because deposit informationhas been provided in previous responses to discovery propounded by discovery in theform of bank statements. In addition, some of the information requested is notavailable to Respondent, but may be available from the various institutions where hebanks.RESPONSE TO REQUEST NO. 9: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 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 Respondent's possession. Theinformation requested should be available from CSldentity located at 7500 RialtoBlvd., #260, Austin, Texas 78735.RESPONDENTS RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX5