Petitioner Request for Production of Documents

Mai 0//Ginny Edmunds5851 Blazing Star LaneSan Diego, CA 92130Telephone: (619)851-8236SUPERIOR COURT OF CALIFORNIAFOR THE COUNTY OF SAN DIEGOIn Re the marriage of:Petitioner: GINNY CALDWELLandRespondent: MICHAEL CALDWELLCase Number: ER 0479REQUEST FOR PRODUCTIONand INSPECTION OF DOCUMENTS(C.C.P. A 2031)•DEMANDING PARTY: GINNY CALDWELLREPONDING PARTY: MICHAEL CALDWELLSET NUMBER: FOURPlease take notice that petitioner, requests, under the Code of Civil Procedure Section 2031, that youproduce and permit the inspection and copying or photographing, by on or on behalf of her, of thedocuments, papers, books, accounts, letters, photographs, objects, or tangible things listed on Exhibit"1" attached hereto. Any documents that have already been provided, do NOT need to be provided atthis time.Petitioner requests that inspection of the above listed items and documents take place on June 28th,2011 in her office at 9541 Ridgehaven Ct, San Diego, CA 92123.Within 30 days after the service of this demand, you must serve a written response subscribed underoath describing the documents you will produce and stating any objections you have to the productionof any documents described herein.These requests are intended to cover and include all documents and records, not previously providedwhich are listed in Exhibit "1" attached hereto, and which are in the possession, custody and/or controlof the petitioner, his attorneys, representatives, or any person, firm or entity acting on his behalf.DEFINITIONS AND INSTRUCTION1. As used throughout these requests, the term "documents" and the term "writing" refers to printed,typewritten or handwritten matter of whatever character, including specifically, but not exclusively,writings, drawings, graphs, tapes, computer discs or print-outs, charts, business records, books of•accounts, ledgers, balance sheets, journals, personal records, accountants' statements, bankstatements, handwritten notes, minutes of meetings, notes of meetings or conversations, catalogs,

•written agreements, check receipts, invoices, bills, any carbon or photographic copies of such materials,and any other data compilations from which information can be obtained by respondent.2. As used throughout these requests, additional terms and phrases shall be defined as follows:a. the term "person" shall include all natural persons, corporations, partnerships, associationsand any other kind of business or legal entity.b. the term petitioner used herein shall refer to Ginny Caldwell.c. The term "respondent" used herein shall refer to Michael Caldwell.d. The term "you" shall refer to Michael Caldwell.e. The term "your" shall refer to anything that is controlled by Michael Caldwell, or in whichMichael Caldwell has use of or access to.f. The term "your former spouse" shall refer to Ginny Caldwell.g. The term "to date" shall refer to the date on which you deliver the documents and thingsrequested herein.3. Each request for any document shall be deemed to call for production of the original documents,to the extent that they are subject, either directly or indirectly, to the control of the respondent. Eachrequest should be considered as including all copies and, to the extent applicable, preliminary drafts ofdocuments which, as to content, differ in any respect from the original or final draft or from each other(e.g., by reason of handwritten notes or comments having been added to one copy of a document butnot to the original or other copes thereof).•4. If you claim any documents responsive to these requests are protected from production by anyprivilege, specify which privilege and identify those documents to which you claim the privilege applies.5. It is your obligation to not only provide documents within your possession, but to contact allaccountants, doctors, agents, attorneys, or any individual who has worked on your behalf to obtain thedocuments requested within the request for production of documents. A production of documentswhich consists only of documents within your possession, without any efforts to obtain all documentsknown to you, will not satisfy the production called for herein.Date:Ginny Edmunds, Petitioner•

2)27 Copy•EXHIBIT "1"For the period of January 2000-Date of Production (unless a different time period is specified), unlessthose documents have been provided in full within the last 2.5 years:1. All Federal and State Income Tax Returns filed by you, together with accompanying worksheetsincluding W-2, K-1 and 1099 forms for 2000, 2002, 2004, 2010.2. In respect to your employment, all documents which set forth the following information:a. your earnings, draws, bonuses, commissions, or other incomeb. payroll deductions of any kindc. the terms and conditions of your employmentd. pay raisese. promotionsf. your interest in pension plans, profit sharing plans, retirement plans, and stock plans,including the value of your interest in such plans and stock options received, whether exercised or notas of the date of the dispositiong. records of travel, including dates of travel, destinations, expense payments and/orreimbursements, frequent flyer mileage accumulated.•3. Records which show all fringe benefits available to you through your employment and from anyentity in which you had a legal or equitable ownership interest, including but not limited to suchbenefits as reimbursement or payment of rent, vehicle expenses, meals and entertainment, andpremiums for life, health and disability insurance.4. All records indicating all funds received by you from any source other than CSldentity, including butnot limited to rental or investment income.5. For all bank, credit union, or investment firm checking and savings accounts held in your namealone or with anyone else that were utilized primarily for personal rather than business purposes: allcheck registers, check stubs, cancelled or duplicate checks, and monthly or quarterly accountstatements.6. For all bank, credit union, or investment firm checking and savings accounts held in your namealone or with anyone else that were utilized primarily for business rather than personal purposes: allcheck registers, check stubs, cancelled or duplicate checks, and monthly or quarterly accountstatements.7. All bank statements of family members or partners, including Marilyn Weakly, where youtransferred money to said accounts from January 2000 to date of production.•8. Any and all electronic files or accounting software data files, including but not limited toQuickbooks for MJC Enterprises and any other company owned or partly owned by Michael Caldwellfrom January 2000-Date of production.

9. Copies of all certificates of deposit, stock certificates or shares, bonds or other securities held inyour name or in the name of your wife, Marilyn Weakly, or in the name of some other person or personsbut held for your benefit.10. All brokerage account statements reflecting assets owned by you individually or jointly with anyperson or entity. Excluding those already provided.11. All records pertaining to stock options in any corporation or other entity, both those exercised orthose not yet exercised.12. All statements, summaries, accounts and ledgers reflecting or explaining the nature, amount,terms, and conditions of payment to you of retirement, pension, IRA, KEOGH, profit sharing, or deferredor contingent compensation benefits as a result of your employment January 2000-date of production.13. All deeds relating to real property in which you appeared as grantee, trustee or beneficiary, andincluding all deeds that were held for your benefit by some other person or persons. (Include all deedsof trust in which you appear as grantor, grantee, trustor or beneficiary even though the propertyinvolved no longer exists or a beneficial interest therein is no longer claimed.)14. All deposit receipts, escrow instructions, escrow closing statements and title insurance policiesrespecting any real property in which you had an interest at any time from June 14, 1990-date ofproduction.15. All certificates of ownership and/or registration certificates relating to automobiles, trucks,motorcycles, motorhomes, boats, water vessels, airplanes, aircraft, trailers and/or vehicles in which youhad an interest, and all purchase agreements or contracts for such properties, including any certificatesof ownership held by you or on your behalf.16. All financial statements, statements of net worth, or loan applications given by you to anyfinancial institution or creditor.17. All documents which set forth the debts or obligations claimed to be owed by you to creditors forpersonal debts.18. All monthly statements reflecting purchases and payments you have made on credit cards and/orcharge accounts, including but not limited to Visa, MasterCard, Amex, Diners Club, gasoline credit cardsand department store charge accounts, including accounts that are held in your name and/or the nameof any other person other than yourself.19. All mortgage or loan statements or other documents setting forth the amount of principal andinterest paid on a regular basis towards mortgages or loans on any real property owned by you orpartially owned by you.•20. Any and all documents which set forth rental or lease agreements with any tenants or lessees inwhich you have an interest.

•21. Any and all documents reflecting rental agreements and /or monthly rent payments made to yourlandlord for your personal residence for the period of January 2000 to the present.22. Any and all records of any rents paid by you or by any company in which you have primaryinterest from January 2000 to date of production.23. All payments made to a third party for paying bills, gifts, and any other monetary transfer ofmonies exceeding $100. This request includes the date, amount, and reason for transfer for period ofJanuary 2000-date of production. Any payments already reflected on credit card statements need not beproduced at this time.24. All payments made on behalf of another person or entity paying for a third party service or bill forthat other entity. This request includes payments made either personally or from any business in whichyou claim a partial interest. January 2000-date of production.25. Any income received from any work performed, from January 1, 1998-date of production, even ifthat income is not reported on the income tax returns.26. A detailed explanation for all transfers made to other parties from any of your checking, savings,or other financial accounts.••