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Document Demands to Judgment Debtor

Document Demands to Judgment Debtor

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Published by gernsby935
a comprehensive set of document requests to be served on a judgment debtor
a comprehensive set of document requests to be served on a judgment debtor

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Categories:Types, Business/Law
Published by: gernsby935 on Jan 28, 2013
Copyright:Attribution Non-commercial

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11/14/2013

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 ___________________________________________________________________________ 
JUDGMENT CREDITOR/PLAINTIFF’S DEMANDS FOR PRODUCTION PROPOUNDED TO JUDGMENTDEBTOR/ DEFENDANT – SET NO. 1
 ____________/pldg/Post-Jdgmt DFP-1-012813
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SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELES - WEST DISTRICT
 
 ______________,Plaintiff,v. ______________, et al.,Defendants.)))))))))))CASE NO. ________________ 
JUDGMENT CREDITOR’S POST JUDGMENTDEMANDS FOR PRODUCTION PROPOUNDEDTO JUDGMENT DEBTOR/DEFENDANT - SETNO. 1PROPOUNDING PARTY: JUDGMENT CREDITOR/PLAINTIFF ________________ RESPONDING PARTY: JUDGMENT DEBTOR/DEFENDANT ________________ SET NO.: ONE
Judgment Creditor/Plaintiff Richard Ziman hereby demands, pursuant to Code of CivilProcedure § 2031.010,
et seq.
, that Judgment Debtor/Defendant ________ (“Debtor”) produceand permit the inspection and copying of the following writings, documents and thingsdescribed below, at the offices of David L. Gernsbacher, 9107 Wilshire Boulevard, Suite 450,Beverly Hills, California 90210, within 30 days after service of these Post-Judgment Demands forProduction - Set No. 1.In responding to these Demands for Production, Debtor is obligated to furnish allinformation which is available to Debtor, including that which has been obtained by, andwhich is now in the possession, custody and/or control of, Debtor’s counsel, employees,DAVID L. GERNSBACHER SBN895969107 Wilshire Blvd Ste 450Beverly Hills CA 90210-5535Tel: 310-550-0125Fax: 310-550-0608Email: dgernsbacher@dlglaw.comAttorney for Judgment Creditor/Plaintiff ____________ 
 
 ___________________________________________________________________________ 
JUDGMENT CREDITOR/PLAINTIFF’S DEMANDS FOR PRODUCTION PROPOUNDED TO JUDGMENTDEBTOR/ DEFENDANT – SET NO. 1
 ____________/pldg/Post-Jdgmt DFP-1-012813
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agents, insurers, independent contractors, representatives, successors, assigns or others,and not merely information known by Debtor or of Debtor’s own knowledge.
DEFINITIONS
1. “WRITINGS” means:a. All written, typed, or other graphic materials of any kind or nature, and any othertangible thing by which information or data is stored, including, without limitation, any writingsas defined by Evidence Code section 250, including any originals as defined by EvidenceCode section 255, and any duplicates as defined by Evidence Code section 260, any drawing,film, graph, chart, photograph, phone record, mechanical or electrical sound recording, ortranscript thereof, any retrievable data, whether in computer storage, carded, punched, taped,coded or stored electronically, electrostatically, electromagnetically, or otherwise, and anyother data compilation from which information can be obtained (including, without limitation, allemails and attachments thereto).b. All agreements, draft agreements, calendars, calendar appointment logs, telephonemessages, telephone logs, forms, facsimile transmissions, cancelled checks, bankstatements, financial statements, loan applications, leases, diaries, worksheets, abstracts,summaries, notes, jottings, audits, charts, diagrams, newspapers, expense reports,appraisals, rent rolls, income tax returns, title reports, inspection reports, tax notices,privileged communication logs, papers, books, communications, emails, letters, reports,proposals, letters of intent, commitment letters, loan applications, correspondence,memoranda, telegrams, cables, notations, work papers, draft documents, statements,opinions, studies, affidavits, declarations, analyses, evaluations, transcripts, minutes,recordings, tapes, photographs, slides, films, and any other sound or visual recordings on anymedia, contracts, instructions, charts, manuals, brochures, publications, schedules, computerprintouts, microfilm, books of account, journals, ledgers, records, and all things similar to anyof the foregoing however denominated, including all partial and complete copies, drafts andfinal versions thereof, and attachments and enclosures therewith.c. All materials as described above within the possession, custody or control of
 
 ___________________________________________________________________________ 
JUDGMENT CREDITOR/PLAINTIFF’S DEMANDS FOR PRODUCTION PROPOUNDED TO JUDGMENTDEBTOR/ DEFENDANT – SET NO. 1
 ____________/pldg/Post-Jdgmt DFP-1-012813
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Judgment Debtor/Defendant ________ (“Debtor”) or any of his duly authorizedrepresentatives, including employees, attorneys, accountants, consultants, advisors, agentsor other representatives. Without limiting the term “control,” a document is deemed to bewithin the control of Debtor if Debtor has ownership, possession or custody of the document,or the right to secure the document from any person or public or private entity having physicalpossession thereof.2. “DEBTOR” means Judgment Debtor/Defendant ________________ or any of his dulyauthorized representatives, including employees, attorneys, accountants, consultants,advisors, agents or other representatives.3. “CONCERNING” means referring to, relating to, concerning, involving, in connectionwith, relevant to, comprising, mentioning, evidencing, supporting and establishing.
WRITINGS TO BE PRODUCED
1. All DEBTOR’s personal and business checking account checks from March 2010 tothe present.2. All DEBTOR’s personal and business checking account deposit slips from March2010 to the present.3. All DEBTOR’s personal and business checking account statements from March 2010to the present.4. All DEBTOR’s personal and business savings account checks from March 2010 tothe present.5. All DEBTOR’s personal and business savings account deposit slips from March 2010to the present.6. All DEBTOR’s personal and business savings account statements from March 2010to the present.7. All DEBTOR’s personal and business money market account checks from March2010 to the present.8. All DEBTOR’s personal and business money market account deposit slips fromMarch 2010 to the present.

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