Legal surfer
Junior Member
What is the name of your state? Ohio
Document request. From who? Who do I object to? Statute of limitations defense. Part 3
REQUEST FOR PRODUCTION OF DOCUMENTS
1. Produce all monthly, quarterly, annual, and any other statements from January 1, 2017 through the present for any bank, credit union, or other financial institution in which you have maintained or been signatory on any checking, savings, or other account, and/or certificate of deposit, and/or any other financial product, whether individually, jointly, or otherwise.
2. Produce all monthly, quarterly, annual, and any other statements from January 1, 2017 through the present for any account maintained by you or for your benefit with any broker or brokerage firm.
3. Produce your federal and state tax returns for the tax years 2016, 2017, and 2018.
4. Produce W-2's and 1099's issued to or for you for the tax years 2016, 2017, and 2018.
5. Produce your most recent pay stub and/or wage statement.
6. Produce all trust documents for which you are a beneficiary.
7. Produce documents showing stocks, bonds, mutual funds, and /or other investments held by you currently and/or at any time during any of the following years: 2016, 2017, 2018 and 2019.
8. Produce documents showing your ownership interest in any partnership, limited partnership, corporation, limited liability company, sole proprietorship, or any other legal or business entity during any of the following years: 2016, 2017, 2018 and 2019.
9. Produce all financial statements by, for or pertaining to you (individually or with any other person(s) or entities), including, but not limited to, those prepared or provided in relation to any loan, refinance, guarantee or other financial or business transaction, loan, or refinance made in any of the following years: 2016, 2017, 2018 and 2019.
10. Produce documents showing your ownership interest in any real property during any of the following years: 2016, 2017, 2018 and 2019.
11. Produce the current mortgage statement(s) for any real property you currently own.
12. Produce all documents regarding cash transfers made by you or at your direction to any person in excess of $10,000 made in any of the following years: 2016, 2017, 2018 and 2019.
13. Produce all documents regarding the transfer of any assets made by you or at your direction having a value in excess of $10,000 made in any of the following years: 2016, 2017, 2018 and 2019.
14. Produce documents showing or identifying any claim or lawsuit you have against any person or entity.
15. Produce documents regarding any precious metals owned by you and having a value separately or in the aggregate in excess of $10,000.
16. Produce documents showing the insuring of any art work, sports memorabilia, sports card collections, coin collections, stamp collections, or other antiques or collectibles on which you have obtained insurance in any of the following years: 2016, 2017, 2018 and 2019, including, but not limited to, producing the declaration page showing the amount for which the foregoing are insured.
17. Produce documents showing any art work, sports memorabilia, sports card collections, coin collections, stamp collections, or other antiques or collectibles owned by you, separately or with any person(s) or entity/entities currently and/or in any of the following years: 2016, 2017, 2018 and 2019.
18. Produce documents, including insurance documents, showing the value and/or insured amount of any jewelry you currently own and/or in which you owned any interest in any of the following years: 2016, 2017, 2018 and 2019.
19. Produce documents showing any motor vehicle or water craft which you currently own and/or in which you owned any interest in any of the following years: 2016, 2017, 2018 and 2019.
20. Produce documents showing any life insurance policies and the cash surrender value thereof for any life insurance policies that were in effect in any of the following years: 2016, 2017, 2018 and 2019.
21. Produce all lease agreements currently in effect on any A) any property in which you have an ownership interest directly; B) any property owned by a legal entity in which you have any ownership interest; or C) any property managed by you or any legal entity in which you own an interest.
22. Produce any balance sheets, profit or loss statements, and inventories created in or showing information pertaining to the years 2016, 2017, 2018 and 2019.
Respectfully submitted,
Signature
Partner-of-law-firm-full-name
Head-of-law-firm-full-name
Partner-of-law-firm-full-name
Partner-of-law-firm-full-address
Partner-of-law-firm-phone-number
Partner-of-law-firm-email
Head-of-law-firm-full-name
Head-of-law-firm-full-address
Head-of-law-firm-phone-number
Head-of-law-firm-email
CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing Request for Production of Documents was served by ordinary U.S. Mail, postage prepaid, this 15th day of January 2020 upon:
Defendant-husband-and-wife-full-names
Defendant-husband-and-wife-full-address
Signature
Partner-of-law-firm-full-name
Head-of-law-firm-full-name
(In bold print) This is a communication from a debt collector. This is an attempt to collect a debt. Any information obtained will be used for that purpose.
Continued on part 4.
Document request. From who? Who do I object to? Statute of limitations defense. Part 3
REQUEST FOR PRODUCTION OF DOCUMENTS
1. Produce all monthly, quarterly, annual, and any other statements from January 1, 2017 through the present for any bank, credit union, or other financial institution in which you have maintained or been signatory on any checking, savings, or other account, and/or certificate of deposit, and/or any other financial product, whether individually, jointly, or otherwise.
2. Produce all monthly, quarterly, annual, and any other statements from January 1, 2017 through the present for any account maintained by you or for your benefit with any broker or brokerage firm.
3. Produce your federal and state tax returns for the tax years 2016, 2017, and 2018.
4. Produce W-2's and 1099's issued to or for you for the tax years 2016, 2017, and 2018.
5. Produce your most recent pay stub and/or wage statement.
6. Produce all trust documents for which you are a beneficiary.
7. Produce documents showing stocks, bonds, mutual funds, and /or other investments held by you currently and/or at any time during any of the following years: 2016, 2017, 2018 and 2019.
8. Produce documents showing your ownership interest in any partnership, limited partnership, corporation, limited liability company, sole proprietorship, or any other legal or business entity during any of the following years: 2016, 2017, 2018 and 2019.
9. Produce all financial statements by, for or pertaining to you (individually or with any other person(s) or entities), including, but not limited to, those prepared or provided in relation to any loan, refinance, guarantee or other financial or business transaction, loan, or refinance made in any of the following years: 2016, 2017, 2018 and 2019.
10. Produce documents showing your ownership interest in any real property during any of the following years: 2016, 2017, 2018 and 2019.
11. Produce the current mortgage statement(s) for any real property you currently own.
12. Produce all documents regarding cash transfers made by you or at your direction to any person in excess of $10,000 made in any of the following years: 2016, 2017, 2018 and 2019.
13. Produce all documents regarding the transfer of any assets made by you or at your direction having a value in excess of $10,000 made in any of the following years: 2016, 2017, 2018 and 2019.
14. Produce documents showing or identifying any claim or lawsuit you have against any person or entity.
15. Produce documents regarding any precious metals owned by you and having a value separately or in the aggregate in excess of $10,000.
16. Produce documents showing the insuring of any art work, sports memorabilia, sports card collections, coin collections, stamp collections, or other antiques or collectibles on which you have obtained insurance in any of the following years: 2016, 2017, 2018 and 2019, including, but not limited to, producing the declaration page showing the amount for which the foregoing are insured.
17. Produce documents showing any art work, sports memorabilia, sports card collections, coin collections, stamp collections, or other antiques or collectibles owned by you, separately or with any person(s) or entity/entities currently and/or in any of the following years: 2016, 2017, 2018 and 2019.
18. Produce documents, including insurance documents, showing the value and/or insured amount of any jewelry you currently own and/or in which you owned any interest in any of the following years: 2016, 2017, 2018 and 2019.
19. Produce documents showing any motor vehicle or water craft which you currently own and/or in which you owned any interest in any of the following years: 2016, 2017, 2018 and 2019.
20. Produce documents showing any life insurance policies and the cash surrender value thereof for any life insurance policies that were in effect in any of the following years: 2016, 2017, 2018 and 2019.
21. Produce all lease agreements currently in effect on any A) any property in which you have an ownership interest directly; B) any property owned by a legal entity in which you have any ownership interest; or C) any property managed by you or any legal entity in which you own an interest.
22. Produce any balance sheets, profit or loss statements, and inventories created in or showing information pertaining to the years 2016, 2017, 2018 and 2019.
Respectfully submitted,
Signature
Partner-of-law-firm-full-name
Head-of-law-firm-full-name
Partner-of-law-firm-full-name
Partner-of-law-firm-full-address
Partner-of-law-firm-phone-number
Partner-of-law-firm-email
Head-of-law-firm-full-name
Head-of-law-firm-full-address
Head-of-law-firm-phone-number
Head-of-law-firm-email
CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing Request for Production of Documents was served by ordinary U.S. Mail, postage prepaid, this 15th day of January 2020 upon:
Defendant-husband-and-wife-full-names
Defendant-husband-and-wife-full-address
Signature
Partner-of-law-firm-full-name
Head-of-law-firm-full-name
(In bold print) This is a communication from a debt collector. This is an attempt to collect a debt. Any information obtained will be used for that purpose.
Continued on part 4.
