Petitioner Request for Production of Documents

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•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.
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Petitioner Request for Production of Documents

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