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Petitioner Request for Production of Documents

Petitioner Request for Production of Documents

Petitioner Request for Production of Documents

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9. Copies <strong>of</strong> all certificates <strong>of</strong> deposit, stock certificates or shares, bonds or other securities held inyour name or in the name <strong>of</strong> your wife, Marilyn Weakly, or in the name <strong>of</strong> some other person or personsbut held <strong>for</strong> 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 <strong>of</strong> payment to you <strong>of</strong> retirement, pension, IRA, KEOGH, pr<strong>of</strong>it sharing, or deferredor contingent compensation benefits as a result <strong>of</strong> your employment January 2000-date <strong>of</strong> production.13. All deeds relating to real property in which you appeared as grantee, trustee or beneficiary, andincluding all deeds that were held <strong>for</strong> your benefit by some other person or persons. (Include all deeds<strong>of</strong> 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 <strong>of</strong>production.15. All certificates <strong>of</strong> 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 <strong>for</strong> such properties, including any certificates<strong>of</strong> ownership held by you or on your behalf.16. All financial statements, statements <strong>of</strong> net worth, or loan applications given by you to anyfinancial institution or creditor.17. All documents which set <strong>for</strong>th the debts or obligations claimed to be owed by you to creditors <strong>for</strong>personal 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 name<strong>of</strong> any other person other than yourself.19. All mortgage or loan statements or other documents setting <strong>for</strong>th the amount <strong>of</strong> 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 <strong>for</strong>th rental or lease agreements with any tenants or lessees inwhich you have an interest.

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