Griever/2005-09-28 Plaintiffs Respond to Document Requests
Notes
- Official Title: plaintiffs' responses to defendants' first request for production of documents and notice to produce at trial
- Submitted to the court on 2005-09-28; received by Plaintiff Nick on 2005-09-30.
- Links have been added for purposes of cross-reference and clarity; they were not present in the original printed document.
- Typographical corrections are enclosed in square brackets: [corrected text]
Nick Notes
- As far as I can tell, this document was composed by my legal counsel without a verbatim review by me, probably based on one or more phone conversations we had and/or emails I sent to said counsel. There are some minor inaccuracies and omissions in the answers; I will attempt to add clarifying notes to this page once I have finished transcribing the current batch of documents.
Contents
The majority of documents responsive to Defendant's first Request for Production of Documents and Notice to Produce at Trial may be accessed through this website: http://wiki.hypertwins.org/index.php/2005-09-15_Documents_requested_by_lawyer
1.
All invoices, computer-generated documents (or hand-written) which related to the business of Red House Media/Cox-Staddon Enterprises, Inc. and/or vbz.net.
Documents are or will be produced.
2.
All income tax returns filed by or on behalf of Plaintiff(s), personal and business, for the period of time beginning 1994 to present.
Plaintiff objects to this request for Production of Documents as burdensome, harassing and over-broad, and for the reason that said request is not reasonably calculated to lead to the discovery of admissable evidence. Without waiving the foregoing objection, income tax returns of the business are hereby produced.
3.
All cash receipt books or cash receipt documents related to business.
Documents are or will be produced.
4.
All document[s] sent to city or county tax boards, assessors or related agencies relating to business beginning 1994 to present.
Documents are or will be produced.
5.
Produce all records that document or identify The ReDistribution Alternative, Inc. as the owner of the merchandise related to vbz.net for the purpose of showing that it would not be the responsibility of the Plaintiff(s), or businesses owned by Nick Staddon, to pay taxes on aforementioned merchandise or for any other purpose.
See documents in response to Request No. 2 and 4.
6.
All documents related to monthly gross sales of the business from the date the business began until the present time.
Documents are or will be produced.
7.
All documents which show accounting of the sale of merchandise purchased and/or sold relating to Red House Media and vbz.net.
Documents are or will be produced.
8.
All letters, writings, correspondence, documents (as defined herein) reflecting communications between the parties.
Documents are or will be produced.
9.
All financial statements and accounting records of each Defendant including, without limitation, balance sheets, income and expense statements, statements of net worth from October 1, 1995 to date.
These are in the possession of Defendants or they are or will be produced.
10.
All documents that evidence, refer to or relate to the Defendants' contractual relationship with Plaintiff(s) or any Defendant.
Documents are or will be produced.
11.
Documentation of all monies that you contend Defendants have owed or still owe the Plaintiff(s).
Documents are or will be produced.
12.
All documentation of all monies paid to the Plaintiff(s) by Defendants since October of 1995.
Documents are or will be produced.
13.
All documents identified by the Plaintiff(s) in response to the First Interrogatories.
Documents are or will be produced.
14.
All documents consulted, referred to, or otherwise utilized in any way in connection with the preparation of your responses to Defendants' First Interrogatories.
Plaintiffs object to this Interrogatory on the basis of work-product doctrine. Without waiving said objection, Plaintiff states that documents consulted have been or will be produced.
15.
All correspondence and other documents which evidence, reflect, or [relate] to any communications between the parties.
Documents are or will be produced.
This 28 day of September, 2005.