ELECTRONICALLY FILED

Washington County Circuit Court

Kyle Sylvester, Circuit Clerk
2021-May-26 15:36:00
72CV-18-3357
C04D05 : 15 Pages

IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS

BRUCE LEWIN PLAINTIFF

VS. CASE NO.: 72CV-18-3357

HANNOVER HOUSE INC.;

MEDALLION RELEASING, INC.;
ERIC PARKINSON; and
D. FREDERICK SHEFTE DEFENDANTS

NOTICE OF FILING

On May 26, 2021, undersigned counsel served the two attached discovery requests: (i)

Interrogatories and (ii) Requests for Production of Documents, upon Defendant Eric Parkinson

by emailing a copy of same to his attorney, Stacy Alexander, to stacy@nixonlaw.com.

Respectfully submitted,

/s/ J. Brian Ferguson

J. Brian Ferguson
Arkansas Bar No. AR2018117
Ferguson Law Firm, PLLC
3333 Pinnacle Hills Pkwy, Suite 410
Rogers, AR 72758
(479) 464-4418 (Telephone)
brian@ozarkfunds.com

Attorney for Bruce Lewin

 IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS

BRUCE LEWIN PLAINTIFF

VS. CASE NO.: 72CV-18-3357

HANNOVER HOUSE INC.;

MEDALLION RELEASING, INC.;
ERIC PARKINSON; and
D. FREDERICK SHEFTE DEFENDANTS

PLAINTIFF’S FIRST SET OF POST-JUDGMENT INTERROGATORIES

Comes Plaintiff, by and through his attorneys, the Ferguson Law Firm, PLLC, and for its first set

of post-judgment interrogatories to be answered by Defendant, Eric Parkinson under oath and

within 30 days pursuant to Rule 33 of the Arkansas Rule of Civil Procedure requests:

INSTRUCTIONS

1. If you object to an interrogatory or request, in whole or in part, but provide an answer

without making any waiver of your objection, please so specify that your answer is without any

waiver of the objection, and the objection so raised, as well as either (a) all responsive

information and documents requested, with said response being so specified, or (b) withholding

the information or documents, and specifying that information is being withheld. If you are

withholding any documents, please identify them, providing enough information to identify the

withheld documents or items for this party and the Court to determine whether the documents or

items should be withheld.

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 2. Where knowledge or information is requested from you, this request includes knowledge

available to or possessed by your agents, representatives, and attorneys, unless privileged.

3. Each interrogatory and each subpart of each interrogatory should be given a separate

response. Interrogatories or subparts thereof may not be combined even when the response given

to the interrogatories and/or their subparts are identical, or substantially similar, however, if an

answer is identical to a previous response, you may answer by reference. However, the answer to

any interrogatory or subpart thereof may not be supplied by reference to a response to any other

interrogatory or subpart thereof, unless the interrogatory or subpart thereof so referred to supplies

a complete and accurate response to the individual interrogatory or subpart thereof which is being

responded to initially.

4. If you are unable to provide an accurate answer to an interrogatory, or are uncertain

regarding a response to any item, please provide your best estimate of the information requested,

specifying that the answer is merely an estimate, and that an accurate response cannot be given

by you to the item.

5. If you believe that an interrogatory or request is vague in itself or utilizes vague

wording, please state what you assume the interrogatory or request to be calling for, and then

answer based upon your assumption. If you are unable even to generate an assumption about

what is being requested, please consult Plaintiff’s counsel for a clarification before

answering. Please note that Plaintiff’s counsel will agree to a 3 day extension of time to respond

if the need arises for Defense Counsel to seek clarification from Plaintiff’s counsel as to terms

and scope of an interrogatory or request for production of documents. Due to this instruction and

its generous terms, if Defense counsel objects to an interrogatory or request based upon

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vagueness, Plaintiff’s counsel will respond to such objection with a motion for sanctions for

unnecessary delay, expense, and use of judicial resources.

6. These interrogatories will be deemed to be continuing in nature in order to allow

supplemental answers so that your responses to each item remain accurate and complete if you or

counsel representing you should obtain any further or different information between the time the

answers to these items are made and the time of any trial on the merits.

Definitions and Guidelines

For purposes of these interrogatories, the following definitions and guiding principles

should be used, and will be deemed to apply for purposes of interpreting both topics of inquiry and

responses thereto:

1. “Person”, unless otherwise specified”, includes the plural as well as the singular, and

includes in its meaning any natural person, or artificial or legal entity, including corporations,

partnerships, joint ventures, associations, governmental agencies, groups, organizations, and any

and every other form of entity cognizable at law.

2. “Document” means and includes all written and graphic matter of every kind and

description, whether printed or produced by any process or by hand, whether final draft or

reproduction, whether in the actual or constructive possession, custody or control of the respondent

to a given interrogatory, including any and all written letters, correspondence, memoranda, notes,

statements, transcripts, files, charters, articles of incorporation, securities, bonds, stocks,

certificates of deposit, evidences of debt, contracts, agreements, licenses, memoranda or notes of

telephone or personal conversations, work papers, tapes, charts, reports, books, ledgers, telegrams,

sound recordings, books of account, customer account statements, financial statements, catalogs,

checks, check stubs, and written statements of witnesses or other persons having knowledge

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pertaining to the pertinent facts requested or relating to the interrogatory or subpart thereof,

whether or not these documents are claimed to be privileged against discovery on any ground.

3. “You” or “your” means the person or entity to which these Interogatories is directed, as

well as his, her, or its agents, representatives, attorneys, experts, insurers, executors,

administrators, or anyone acting on behalf of the person or entity, including any and all persons

acting in the above-described capacity on behalf or purportedly on behalf of the person or entity

to which the request or subpoena is directed.

4. “Identify” means, when used with reference to an individual person, organization,

corporation or association, to state the full name, home and work addresses, e-mail address, home

and business telephone numbers, present or last known position and business affiliation and

position both in the past and at the time said interrogatory or subpart thereof is being responded

to.

The term “identify” further means, when used with reference to a document, to state the

date it was created, its author, the signatory, if different, the addressee, the recipient of all copies,

the type of document (e.g. chart, memorandum, letter, or other written document) and its present

or last known custodian.

5. “Describe” means that the person or entity to whom the interrogatory or subpart thereof

is directed should state what is requested to be described, including all facts and opinions known

and held regarding, relating to, or pertinent to what is requested to be described, and (i) the identity

of each person or entity involved or having any knowledge of each fact or opinion that relates to

what is so described, (ii) the identity of each document evidencing the answer or response given

or relating, referring or pertaining to said subject-matter in any way, and (iii) all relevant or

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material dates and time periods, specifying the way in which said dates or time periods are

pertinent to the subject-matter described.

INTERROGATORY NO. 1: Please state your name, current residential address, and telephone

number. If your current residence is rented, please also state:

A. the amount of the monthly rent;

B. the beginning date and end date of the lease;

C. the amount of any deposits you made to the landlord;

D. the name of the lessee on the lease;

E. the name and contact details of your landlord; and

F. the financial account used to pay the last rental payment, including the name on the

account and the name and address of the financial institution from which the funds were

drawn. If paid in cash and not by check, wire or ACH transfer, please so state.

INTERROGATORY NO. 2: Please state whether you have an office independent of your home

where you preform work, regardless of whether you own said office. If the answer is in the

affirmative, please state the address of your office.

INTERROGATORY NO. 3: Please list by name and address, the percentage ownership of all

business entities in which you own any interest in whatsoever, including, but not limited to a

membership interest in an LLC, an interest in any type of partnership, or shares of stock in a

corporation either public or non-public. Include common and preferred shares owned in any

corporation.

INTERROGATORY NO. 4: Please state the name of any “fictitious” entity under which you

have done business as in the last two years.

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INTERROGATORY NO. 5: For all non-publicly traded business entities listed in response to

interrogatory No. 3, please state all others who own a share in the business listed to the best of

your knowledge and/or belief and the percentage of the business that they own.

INTERROGATORY NO. 6: Please list all businesses which any entity listed in response to

Interrogatory No. 3 has an interest in, to the best of your knowledge and/or belief.

INTERROGATORY NO. 7: For all charitable contributions you have made in the last four

years, please list and/or state the following:

(A) the amount and/or character of the contribution (e.g.. did you donate furniture instead

of money);

(B) the organization the contribution was made to;

(C) approximate date of all charitable contributions; and

(D) your approximate net worth at the time of each contribution.

INTERROGATORY NO. 8: For all gifts you have made in the last four years, please list

and/or state the following:

(A) the amount and/or character of the gift (e.g., what did you give if you gave something

other than money);

(B) the person or organization the gift was made to;

(C) approximate date of each gift; and

(D) your approximate net worth at the time of each gift.

INTERROGATORY NO. 9: For all personal1 or real property you have transferred for yourself

or on behalf of any entity within the last four years, please list and/or state the following:

1 For purposes of this interrogatory, you may limit your response for personal property to personal property that has
a value of more than $250 dollars. Value does not mean that it sold for more than $250 dollars, though. If there is any
uncertainty about if an item is worth $250, please list it.

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 (A) a description of the property transferred, including its estimated value;

(B) the name of the person or organization that the property was transferred to;

(C) the approximate date of the transfer;

(D) the consideration you received in exchange for the transfer; and

(E) your approximate net worth at the time of each transfer.

INTERROGATORY NO. 10: For all property (real and personal) that you have an ownership

interest in whatsoever, please provide and/or state:

(A) a description of the property;

(B) whether the property is subject to any lien and if so who the lien is in favor of;

(C) If the property is subject to a lien, please state if the lien is perfected and if so how the

lien is perfect, and if perfected by a UCC filing, please provide the filing or

identification number of the UCC filing;

(D) The type of interest held. For example, fee simple, leasehold, mineral interests, etc.

(E) the location of the property; and

(F) whether anyone else to your knowledge and belief has an ownership interest in the

property.

In answering Interrogatory 10, you may omit vehicles, trailers and boats which are

covered in greater detail in subsequent Interrogatories.

INTERROGATORY NO. 11: For all monies and/or revenues you have received and/or been

paid within the last year, please state the following:

(A). the name of the person or business making payment to you;

(B). the reasons why such payment was made to you (e.g., what property did you rent or

what work did you perform in consideration for the payment);

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 (C). what you did with such monies.

INTERROGATORY NO. 12: For every bank or investment firm where you currently, or

within the last 180 days, have held (i.e., owned or possessed authority to draw funds) a banking

account, IRA, or investment account, or any other type of account with a bank or investment

firm please state:

(A) the name and address of each bank or investment firm;

(B) the number of each account you hold with them;

(C) the amount of money currently in the account;

(D) the highest amount of money that has been in the account within the last 180 days.

INTERROGATORY NO. 13: List the names of all persons or legal entities that owe you

money as of 5/26/2021, providing the name and address for each and the amount owed.

INTERROGATORY NO. 14: If you are a beneficiary under any trust, or will in probate, state

the name of the trust or decedent, and the name and address of the trustee of each such trust or

personal representative of the estate, and the amount to which you are entitled under the trust or

will.

INTERROGATORY NO. 15: State the name and address for all entities to which you have

given a financial statement or applied for a loan with within the last five years.

INTERROGATORY NO. 16: State the name of any entity for which you have held yourself

out to own, control, or manage in the past two years.

INTERROGATORY NO. 17: State whether you or any entity owned, managed or controlled

by you still occupies or leases premises at 2200 S. Old Missouri Road in Springdale, Arkansas.

INTERROGATORY NO. 18: If your answer to Interrogatory 23 is in the affirmative, please

state:

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 A. the person or entity which occupies or leases the space;

B. the business activity that is conducted from the premises; and

C. the assets located at the premises, and the owner of those assets.

INTERROGATORY NO. 19: Please identify by make, model, and VIN number all vehicles

and trailers owned by: you; any entity which you own, control, or manage; or any trust to which

you are a beneficiary or trustee. Along with the make, model, and VIN number, please state the

owner(s) of the vehicle by percentage, its location, and the amounts of any liens.

INTERROGATORY NO. 20: Please identify by make, model, and Hull number all boats

owned by: you; any entity which you own, control, or manage; or any trust to which you are a

beneficiary or trustee. Along with the make, model, and Hull number, please state the owner(s)

of the vehicle by percentage, its location, and the amounts of any liens.

INTERROGATORY NO. 21: If the 2004 Chaparral boat which was once owned by the

Catmax Trust is not included in your answer to Interrogatory 26, please state:

A. The date it was transferred from Catmax;

B. The consideration Catmax received for the transfer;

C. The name address and contact details of the transferor; and

D. The last known location of the boat and the date of that last known location.

INTERROGATORY NO. 22: For every credit card where you are an obligor, or a person

authorized to draw credit, please state:

(A) the name and address of each credit card firm;

(B) the name and address of the borrower on the account;

(C) the number of each account from which you may draw credit;

(D) the maximum credit amount allowed to be drawn;

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 (E) the balance of the account as of March 31, 2019;

(F) the date and amount of the last payment;

(G) the total amounts of payments paid on the account in the last year; and

(H) the source of the funds used to make each of the payments made in the last year.

INTERROGATORY NO. 23: Please describe any role you have as an officer or director of

Vodwiz, Inc.

INTERROGATORY NO. 24: Please identify the shareholders of Vodwiz, Inc.

INTERROGATORY NO. 25: Please describe all tangible and intangible assets owned or

controlled by Vodwiz, Inc.

Dated: May 26, 2021

Respectfully submitted,

/s/ J. Brian Ferguson________________________

J. Brian Ferguson
Arkansas Bar No. AR2018117
Ferguson Law Firm, PLLC
3333 Pinnacle Hills Pkwy, Suite 410
Rogers, AR 72758
(479) 464-4418 (Telephone)
brian@ozarkfunds.com

Attorney for Bruce Lewin

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 IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS

BRUCE LEWIN PLAINTIFF

VS. CASE NO.: 72CV-18-3357

HANNOVER HOUSE INC.;

MEDALLION RELEASING, INC.;
ERIC PARKINSON; and
D. FREDERICK SHEFTE DEFENDANTS

PLAINTIFF’S FIRST SET OF POST-JUDGMENT REQUEST FOR

PRODUCTION OF DOCUMENTS

Comes Plaintiff, by and through his attorneys, Ferguson Law Firm, PLLC, and for her first

set of post-judgment request for production of documents to be answered by Defendant, Eric

Parkinson, within 30 days pursuant to the Arkansas Rules of Civil Procedure requests Eric

Parkinson to produce the following:

1. A Copy of your state and federal income tax returns for 2017, 2018, 2019, and 2020, including

all attachments K-1s.

2. A copy of any estimated income tax return for 2020 if none has been filed.

3. A copy of all personal and business bank statements, including canceled checks, for the 24

months immediately preceding the date of this request. This request includes business accounts

which are within your possession or control and/or for which you have a debit card or signing

authority.

4. Documents sufficient to show the source of any deposit made into any account you identify
 pursuant to the above request bank statements for the 24 months immediately preceding the

date of this request.

5. A copy of all business and personal accounts receivable ledgers within your possession or

control for the 24 months immediately preceding the date of this request for yourself and any

entity in which you hold a legal or equitable interest.

6. A copy of all deeds, leases, mortgages, or any other written instruments evidencing any interest

or ownership in real property at any time within the last 7 years. This should include, but is

not limited to, a copy of your current residential lease and for the lease at 355 N. College

Avenue in Fayetteville, AR occupied or used by Hannover House, Inc., or Vodwiz, Inc.

7. A copy of bills of sale or other written evidence of any personal or real property purchased or

transferred during the last four years.

8. Copies of all financial statements prepared or executed by you within the last four years.

9. A copy of all stock certificates or other evidence of ownership of stocks and bonds held

individually or jointly by or with you, including copies of any stock brokerage accounts

maintained in the 3 years immediately preceding the date of this request.

10. A copy of all policies of life insurance owned by you, regardless of the insured or

beneficiary.

11. Copy of all wills or trust agreements which you have made or which you are a

beneficiary or trustee, whether or not you have a present income interest.

12. Copies of all contracts on which you are now preforming services (including consulting

services) or upon which someone is indebted to you for services furnished.

13. A copy of all insurance policies insuring loss to any property, real or personal, which you

own alone or jointly with any other person or have owned within the last 4 years.

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14. A copy of all bills of sale, deeds, contracts, or other documents showing transfer of any

and all property executed by you personally or jointly with any other person, or by you on

behalf of any business entity during the last four calendar years.

15. Please produce a copy of all partnership agreements or operating agreements and articles

of organization for every LLC which you have any membership interest in (directly or

indirectly) and are within your possession or control. This would include, but is not limited

to, all entities that a trust owns that you are a settlor, beneficiary, or trustee of.

16. Please produce a copy of all by-laws for every corporation in which you have any

ownership interest (directly or indirectly) and are within your possession or control.

17. Please produce a copy all 2017, 2018, 2019, and 2020 tax returns within your possession

or control for all business entities which you have a controlling ownership interest or which

you control. This would include any business entities you control by virtue of being a

director, officer, Trustee, manager, or the like.

18. Please produce a copy of any trust agreement under which you are holding property as a

Trustee.

19. Please produce a copy of all invoices you or any business you control have sent

requesting payment within the last year.

Dated: May 26, 2021

Respectfully submitted,

/s/ J. Brian Ferguson________________________

J. Brian Ferguson
Arkansas Bar No. AR2018117
Ferguson Law Firm, PLLC
3333 Pinnacle Hills Pkwy, Suite 410
Rogers, AR 72758
(479) 464-4418 (Telephone)
brian@ozarkfunds.com

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 Attorney for Bruce Lewin

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