12.07.2015 Views

Petitioner Request for Production of Documents

Petitioner Request for Production of Documents

Petitioner Request for Production of Documents

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2)27 Copy•EXHIBIT "1"For the period <strong>of</strong> January 2000-Date <strong>of</strong> <strong>Production</strong> (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 <strong>for</strong>ms <strong>for</strong> 2000, 2002, 2004, 2010.2. In respect to your employment, all documents which set <strong>for</strong>th the following in<strong>for</strong>mation:a. your earnings, draws, bonuses, commissions, or other incomeb. payroll deductions <strong>of</strong> any kindc. the terms and conditions <strong>of</strong> your employmentd. pay raisese. promotionsf. your interest in pension plans, pr<strong>of</strong>it sharing plans, retirement plans, and stock plans,including the value <strong>of</strong> your interest in such plans and stock options received, whether exercised or notas <strong>of</strong> the date <strong>of</strong> the dispositiong. records <strong>of</strong> travel, including dates <strong>of</strong> 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 <strong>of</strong> rent, vehicle expenses, meals and entertainment, andpremiums <strong>for</strong> 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 <strong>for</strong> 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 <strong>for</strong> business rather than personal purposes: allcheck registers, check stubs, cancelled or duplicate checks, and monthly or quarterly accountstatements.7. All bank statements <strong>of</strong> family members or partners, including Marilyn Weakly, where youtransferred money to said accounts from January 2000 to date <strong>of</strong> production.•8. Any and all electronic files or accounting s<strong>of</strong>tware data files, including but not limited toQuickbooks <strong>for</strong> MJC Enterprises and any other company owned or partly owned by Michael Caldwellfrom January 2000-Date <strong>of</strong> production.

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