Respondent Response to Request for Production of Documents

• •1existed.234567891011121314• 1516171819202122232425262728RESPONSE TO REQUEST NO. 19: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. Respondent responds as follows:Respondent is unable to comply with this request because he does not have access toany tax returns for CSldentity. In order to obtain the requested documentation,Petitioner will need to contact CSIdentity.RESPONSE TO REQUEST NO. 20: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. Respondent responds as follows:Respondent is unable to comply with this request because he does not have access tothe documentation requested. In order to obtain the requested documentation,Petitioner will need to contact CSldentity.RESPONSE TO REQUEST NO. 21: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. Respondent responds as follows:Respondent is unable to comply with this request because he does not have access toany tax returns for Internet Megameeting. In order to obtain the requesteddocumentation, Petitioner will need to contact Internet Megameeting.RESPONSE TO REQUEST NO. 22Respondent objects to this request because it is overly broad as to theexpansive timeframe requested and as such is not reasonably calculated to lead tothe discovery of information relevant to the subject matter of this action nor to thediscovery of admissible evidence, and is therefore burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locateRESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX9