4818-0004-4948.3

KUTAK ROCK LLP

Jeremy S. Williams (VSB No. 77469)

Riverfront Plaza

901 East Byrd Street, Suite 1000

Richmond, Virginia 23219

Telephone: (804) 644-1700

jeremy.williams@kutakrock.com

Counsel for RREF II BB 2014-I Acquisitions, LLC

IN THE UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

_______________________________________________

 )

 In re: ) Chapter 7

)

 SHRIDHAR V. BHAT ) Case No. 19-31691-KLP

)

Debtor. )

_______________________________________________ )

REQUEST FOR EXAMINATION AND 

PRODUCTION OF DOCUMENTS PURSUANT TO RULE 2004

RREF II BB 2014-1 Acquisitions, LLC (the “Creditor”), requests the entry of an Order, 

substantially in the form of Exhibit A attached hereto, pursuant to Rule 2004 of the Federal 

Rules of Bankruptcy, compelling the production of certain documents in the possession of 

Shridhar Bhat (the “Debtor”), Linda Lacova-Bhat (“Mrs. Bhat”), Robert Bhat (“R. Bhat”), 

Capital One, N.A., JPMorgan Chase & Co., PNC Bank, National Association, SunTrust Banks, 

Inc., Branch Banking and Trust Company, Wells Fargo Clearing Services, LLC, Wells Fargo 

Bank, N.A., Asbury Automotive North Carolina L.LC., TransAmerica Life Insurance and its 

related affiliates, Harris, Hardy & Johnstone, P.C., Senior’s First Choice, Inc., Richmond 

Behavioral Health Authority and Correctional Medical Care, Inc. (collectively, the 

“Examinees”), as more specifically set forth on Schedule 1 attached hereto and authorizing the 

examination of the Debtor, Mrs. Bhat and R. Bhat (the “Motion”) and in support thereof, states 

as follows:

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BACKGROUND

The $2 Million Note

1. Lacova-Bhat, L.C. (“Lacova”), Tanglewood Home for Adults, Inc. (“Tanglewood 

Inc.”), Tanglewood Home for Adults, L.C. (“Tanglewood L.C.”), Alleghany Manor LLC a/k/a 

Alleghany Manor LC (“Alleghany Manor” and together with Lacova, Tanglewood Inc. and 

Tanglewood L.C., the “Borrowers”) are indebted to the Creditor pursuant to a Promissory Note 

dated August 27, 2008 in the original principal amount of $2,180,000.00 (as amended, modified 

and/or restated, the “$2 Million Note”). 

2. The $2 Million Note is subject to the terms of that certain Loan Agreement 

dated August 27, 2008 (the “Loan Agreement”). 

3. The $2 Million Note is secured by, among other things: (i) certain real property 

located in Alleghany County, Virginia (the “Property”) pursuant to and as further described in 

that certain Deed of Trust dated August 27, 2008 (the “$2 Million Deed of Trust”) and recorded 

in the Clerk’s Office for Alleghany County (the “Clerk’s Office”) on August 28, 2008 as 

Instrument Number 080002186; and (ii) all leases and rents arising in connection with the 

Property pursuant to an Assignment of Leases and Rents dated August 27, 2008 and recorded in 

the Clerk’s Office on August 28, 2008 as Instrument Number 080002188 (the “Assignment of 

Rents”). 

4. The Debtor personally and unconditionally guaranteed the obligations of Lacova 

due under the $2 Million Note pursuant to a Guaranty Agreement dated August 27, 2008 (the 

“Bhat Guaranty”). 

5. The Irrevocable Trust FBO Robert L. Bhat Under Trust Agreement Dated January 

20, 1997 (“Robert Bhat Trust”), the Irrevocable Trust FBO Nancy Bhat Under Trust Agreement 

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Dated October 17, 2013 (“Dated Nancy Bhat Trust”), and the Irrevocable Trust FBO Nancy Bhat 

(“Undated Nancy Bhat Trust” and together with the Debtor, the Robert Bhat Trust and the Dated 

Nancy Bhat Trust, the “Guarantors”) personally and unconditionally guaranteed the obligations 

of Lacova and Tanglewood L.C. due under the $2 Million Note pursuant to various Guaranty 

Agreement(s) dated October 15, 2013 (collectively, the “Trust Guaranties” and together with the 

Bhat Guaranty, the “Guaranties”). 

The $250k Note

6. The Borrowers are also indebted to the creditor pursuant to a Promissory Note 

dated August 27, 2008 in the original principal amount of $250,000.00 (as amended, modified 

and/or restated, the “$250k Note”). 

7. The $250k Note is also subject to the terms of the Loan Agreement.

8. The $250k Note is secured by, among other things, the Property pursuant to and 

as further described in that certain Deed of Trust dated August 27, 2008 (as amended, modified 

and/or restated, the “$250k Deed of Trust”) and recorded in the Clerk’s Office on August 28, 

2008 as Instrument Number 080002187.

9. The Debtor personally and unconditionally guaranteed the obligations of Lacova 

under the $250k Note pursuant to the Bhat Guaranty.

10. The Robert Bhat Trust, the Dated Nancy Bhat Trust and the Undated Nancy Bhat 

Trust personally and unconditionally guaranteed the obligations of Lacova and Tanglewood L.C. 

due under the $250k Note pursuant to the Trust Guaranties. 

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The $50k Note

11. The Debtor is also indebted to the Creditor pursuant to a Promissory Note dated 

March 22, 2010 in the original principal amount of $50,000.00 (as amended, modified and/or 

restated, the “$50k Note” and together with the $2 Million Note and $250k Note, the “Notes”). 

12. The $50k Note is subject to the terms of that certain BB&T ChoiceLine 

Agreement dated March 27, 2012 (as amended, modified and/or restated, the “ChoiceLine 

Agreement”).

13. The $50k Note is secured by, among other things, the Property pursuant to and as 

further described in that certain Credit Line Deed of Trust (as amended, modified and/or 

restated) and recorded in the Clerk’s Office on December 10, 2012 as Instrument Number 

120002379. 

Default, Judgment and Collection

14. Tanglewood defaulted under the terms of the Notes and on October 30, 2014, the 

Creditor filed a Complaint against the Borrowers and the Guarantors (collectively, the 

“Obligors”) in the Circuit Court for the City of Richmond [Case No. CL14004783-00] seeking 

judgment in connection with the obligations due and owing under the Note (the “Suit”). 

Subsequent thereto and after the Obligors were sanctioned for failing to comply with varioud 

discovery requests, the Creditor and the Obligors executed a Settlement Agreement dated 

January 19, 2016 (the “Settlement Agreement”). 

15. Under the Settlement Agreement, the Obligors were required to make certain 

payments to the Creditor and the Obligors granted the Noteholder a consent order granting 

judgment to be submitted in the event they failed to satisfy their obligations under the Settlement 

Agreement. The Obligors defaulted on their obligations under the Settlement Agreement and on 

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April 3, 2017, the Circuit Court for the City of Richmond entered the Consent Order Granting 

Judgment (the “Judgment”). 

16. Since obtaining Judgment, the Creditor has been working diligently to try and 

collect on the Judgment and to understand the Debtor’s assets and liabilities, including seeking 

the appointment of a receiver with respect to the Property.

1

 During this time, the creditor has 

uncovered a substantial amount of information which is highly disconcerting. Such information 

necessitates the need for the information sought this Motion.

Deposition and Production of Documents from R. Bhat

17. One item of interest is the Debtor’s involvement with King Pin Investors, LLC 

(“KP Investors”) and King Pin Properties, LLC (“KP Properties” and together with KP Investors, 

“King Pin”) which entity owns and operated a bowling alley at 200 N. Otterdale Road, 

Midlothian, VA 23113 (collectively, “King Pin”). In order to better under the relationship 

between King Pin and the Debtor, the Creditor issued various subpoenas the Debtor, R. Bhat and 

other entities. Counsel for the Debtor, who was also representing R. Bhat, the Debtor’s son, 

initially opposed these efforts and filed a motion to quash (“Motion to Quash”) in state court. 

18. The Motion to Quash revolved around whether or not certain entities were owned 

by the Debtor or whether he had a financial interest in such entities. Specifically, the Motion to 

Quash advised that the moving parties, including R. Bhat, King Pin, the Shridhar V. Bhat Office 

of Physicians (the “Doctor’s Office”) and the Central Virginia Health Network, L.C., were 

unrelated to the Debtor and the collection efforts being pursued by the Creditor.

 

1

It is worth noting that since the appointment of a temporary receiver with respect to the Property, the Debtor 

allegedly retained a broker whom he advised to sell the Property as quickly as possible. Such instructions were 

given notwithstanding that any sale would be subject to approval of the Creditor absent satisfaction of the Judgment 

and that the Debtor’s authority to sell the Property was revoked upon entry of an order appointing a receiver.

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19. During a follow up discussion with counsel, the Creditor was again advised that 

the movants, including, specifically King Pin, had no relation whatsoever to the Debtor.

20. Such statement was misleading at best. Based on prior tax returns filed by the 

Debtor, it was apparent that the Debtor had maintained an ownership interest in some or all of 

King Pin. Now, based on the Debtor’s Schedules and Statement of Financial Affairs [Docket 

No. 13], it appears as though the Debtor acknowledges he has an ownership interest in KP

Properties and that had he previously had an ownership interest in KP Investors and that he 

transferred such ownership interest to R. Bhat shortly after the Suit was initiated against him.

21. The Debtor maintains that he has no interest in KP Investors at this time, but R. 

Bhat, who resides in Florida is alleged to be running and managing an entity which operates in 

Richmond. Such assertions seem improbable.

22. In addition, bank records also reflect $17,500 being transferred from the Doctor’s 

Office, owned by the Debtor, to KP Investors, allegedly owned by R. Bhat. Accordingly, the 

evidence seems to reflect that the Debtor is using R. Bhat and King Pin to hide assets from his 

creditors.

23. Upon information and belief, R. Bhat has also received compensation from the 

Doctor’s Office, which is or was previously owned by the Debtor. Specifically, bank records 

reflect checks being issued from the Doctor’s Office to R. Bhat. Again, it is unclear what 

circumstances, other than fraud, would exist whereby the Debtor would be transferring assets to 

R. Bhat.

24. It is also believed that R. Bhat is the beneficiary of the Robert Bhat Trust. Such 

trust may have been established in the midst of litigation with the Creditor and/or the Debtor 

maybe using the Robert Bhat Trust to hide assets from his creditors. 

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25. At this point, it is clear R. Bhat is integrally involved in this case and is likely the 

recipient of fraudulent transfers to the detriment of the Debtor’s creditors.

Deposition and Production of Documents from Mrs. Bhat

26. The Debtor has shown a proclivity to use family members to hide assets from his 

creditors and the Creditor believes that such proclivity likely extends to his wife. Specifically, 

upon information and belief, Mrs. Bhat opened a new bank account with Union Bank & Trust 

just prior to the filing of these bankruptcy proceedings. The Creditor has also identified transfers 

to or from this account to other accounts in which the Debtor has an interest. It is highly likely 

that such actions are related to the filing of these proceedings and to the Debtors efforts to hide 

assets. In addition, she is likely to have information regarding the various entities in which the 

Debtor has asserted or failed to assert an interest.

Production of Documents From Financial Institutions

27. Capital One, N.A., JPMorgan Chase & Co., PNC Bank, National Association, 

SunTrust Banks, Inc., Branch Banking and Trust Company, Wells Fargo Clearing Services, 

LLC, Wells Fargo Bank, N.A. (collectively, the “Banks”) are all identified as financial 

institutions which have serviced either the Debtor or related entities. In some instances, the 

Banks have provided line of credits for which payment information may disclose additional 

assets and/or provide a more comprehensive picture of the Debtor’s liabilities. Review of the 

records of the Banks, as an independent party, is necessary to properly examine the veracity of 

the Debtor’s disclosures.

28. In other instances, some of the Banks hold depository accounts of the Debtor or 

related entities or manage retirement funds for the Debtor or related entities. Accordingly, 

reviewing the records of such Banks will provide direct insight into the Debtor’s assets.

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Asbury Automotive

29. Asbury Automotive North Carolina L.LC. operates as Richmond BMW. Upon 

information and belief the Debtor may own certain assets or be using personal assets in 

connection with a vehicle acquired from this Examinee. In order to determine whether the 

Debtor has accurately disclosed his assets (including the potential sources of payment), the 

production of documents from this entity is necessary.

TransAmerica Life Insurance and its related affiliates

30. Upon information and belief, the Debtor has various policies with TransAmerica 

Life Insurance and its related affiliates despite the fact that no such policies are disclosed on the 

Debtor’s Schedules. Production of these documents directly from the source ensures the 

accuracy and complete disclosure of such information. Given that such policies, to the extent 

they exist, would be assets of the Debtor’s estate, the production of such documents is 

appropriate. 

Harris, Hardy & Johnstone, P.C.

31. Harris, Hardy & Johnson, P.C. served as accountant for the Debtor and 

accordingly is likely best suited to verify the completeness and accuracy of the disclosures set 

forth in the Debtor’s Schedules and Statement of Financial Affairs, including the value and 

ownership interest of the various entities, including King Pin. Such documents would also allow 

the Creditor to independently verify other matters, like the Debtor’s income, all of which relate 

directly to the Debtor’s assets and liabilities.

Senior’s First Choice, Inc., Richmond Behavioral 

Health Authority and Correctional Medical Care, Inc.

32. Based on other documentation previously received, the Creditor believes that the 

Debtor either receives or received income from various other sources and/or had some other 

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relationship with Senior’s First Choice, Inc., Richmond Behavioral Health Authority and 

Correctional Medical Care, Inc. Accordingly, the document request seeks the production of 

documents from these entities as they relate to the Debtor and whether additional undisclosed 

assets may exist.

33. The Creditor is not requesting an examination of any of the entities set forth 

herein, other than the Debtor, Mrs. Bhat and R. Bhat, at this time, but reserves all rights with 

respect thereto. 

WHEREFORE, the Creditor requests the Court enter an Order compelling that within 

15 days of the entry of such an order: (i) the Examinees produce the documents set forth on 

Schedule I attached hereto; and (ii) that upon request, the Debtor, R. Bhat and Nancy Bhat

submit to an examination by the Creditor at a time and place to be agreed upon, but which 

examination shall occur no later than June 14, 2019.

 RREF II BB 2014-I ACQUISITIONS, LLC

 By: /s/ Jeremy S. Williams

 Counsel

KUTAK ROCK LLP

Jeremy S. Williams (VSB No. 77469)

901 East Byrd Street, Suite 1000

Richmond, VA 23219-3500

Telephone: (804) 644-1700 

jeremy.williams@kutakrock.com

 Counsel to RREF II BB 2014-I Acquisitions, LLC

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4818-0004-4948.3

CERTIFICATE OF SERVICE

Pursuant to the Local Rules of this Court, I hereby certify under penalty of perjury that a 

true and correct copy of the foregoing was served to all counsel of record via the Court’s ECF, 

certified mail and/or first-class mail, on April 19, 2019, as follows:

Debtor (by First-Class Mail):

Shridhar Bhat

6331 River Road

Henrico, VA 23229

Counsel (by CM/ECF):

David K. Spiro

Spiro & Browne

6802 Paragon Place, Ste. 410

Richmond, VA 23230

U.S. Trustee (by CM/ECF):

John P. Fitzgerald, III

Office of the U.S. Trustee

701 E. Broad Street, Ste. 4304

Richmond, VA 23219

Asbury Automotive North Carolina L.L.C.

c/o Corporation Service Company, 

Registered Agent

100 Shockoe Slip, 2nd Floor

Richmond, VA 23219

Branch Banking and Trust Company (by 

certified mail)

c/o Christopher L. Henson, Officer

200 West Second Street

Winston-Salem, NC 27101-4019

Capital One, N.A. (by certified mail)

c/o Thomas A. Feil, Treasurer

1680 Capital One Drive

McLean, VA 22102

Correctional Medical Care, Inc.

c/o CT Corporation System, Registered 

Agent

4701 Cox Road, Suite 285

Glen Allen, VA 23060

Harris, Hardy & Johnstone, P.C.

c/o John W. Anderson, Registered Agent

Spotts Fain PC

411 East Franklin St., Ste. 600

Richmond, VA 23219

JPMorgan Chase & Co (by certified mail)

c/o Molly Carpenter, Officer

1111 Polaris Parkway

Columbus, OH 43240

Linda Lacova-Bhat

6331 River Road

Henrico, VA 23229

PNC Bank, N.A. (by certified mail)

c/o Charles E. Bunch, Director

One PPG Place

Pittsburgh, PA 15272

Richmond Behavioral Health Authority

c/o John P. Lindstrom, Ph.D., LCP, CEO

107 South Fifth Street

Richmond, VA 23219

Robert Lacova-Bhat

3470 E. Coast Ave., Apt. 1704

Miami, FL 33137

Senior’s First Choice, Inc.

c/o Michael P. Lafayette

10160 Staples Mill Road

Suite 105

Glen Allen, VA 23060

SunTrust Banks, Inc. (by certified mail)

c/o Allison Dukes, Officer

303 Peachtree St. NE

Atlanta, GA 30308

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Transamerica Life Insurance Company

c/o CT Corporation System, Registered 

Agent

4701 Cox Road, Suite 285

Glen Allen, VA 23060

Wells Fargo Bank, N.A. (by certified mail)

c/o M. Keith Jackson, Officer

45 Fremont Street, 27th Floor

San Francisco, CA 94104

Wells Fargo Clearing Services, LLC

c/o Corporation Service Company, 

Registered Agent

100 Shockoe Slip, 2nd Floor

Richmond, VA 23219

By: /s/ Jeremy S. Williams

 Counsel

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4818-0004-4948.3

EXHIBIT A

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4818-0004-4948.3

KUTAK ROCK LLP

Jeremy S. Williams (VSB No. 77469)

Riverfront Plaza

901 East Byrd Street, Suite 1000

Richmond, Virginia 23219

Telephone: (804) 644-1700

jeremy.williams@kutakrock.com

Counsel for RREF II BB 2014-1 Acquisitions, LLC

IN THE UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

_______________________________________________

 )

 In re: ) Chapter 7

)

 SHRIDHAR V. BHAT ) Case No. 19-31691-KLP

)

Debtor. )

_______________________________________________ )

ORDER GRANTING REQUEST FOR EXAMINATION AND 

PRODUCTION OF DOCUMENTS PURSUANT TO RULE 2004 

THIS MATTER comes before the Court upon the Request for Examination and 

Production of Documents Pursuant to Rule 2004 (the “Motion”) filed by RREF II BB 2014-1

Acquisitions, LLC (the “Creditor”) seeking an order compelling the production of certain 

documents in the possession of Shridhar Bhat (the “Debtor”), Linda Lacova-Bhat (“Mrs. Bhat”), 

Robert Bhat (“R. Bhat”), Capital One, N.A., JPMorgan Chase & Co., PNC Bank, National 

Association, SunTrust Banks, Inc., Branch Banking and Trust Company, Wells Fargo Clearing 

Services, LLC, Wells Fargo Bank, N.A., Asbury Automotive North Carolina L.LC., 

TransAmerica Life Insurance and its related affiliates, Harris, Hardy & Johnstone, P.C., Senior’s 

First Choice, Inc., Richmond Behavioral Health Authority and Correctional Medical Care, Inc. 

(collectively, the “Examinees”) and requesting an examination of the Debtor, R. Bhat and Mrs. 

Bhat pursuant to Rule 2004 of the Federal Rules of Bankruptcy Procedure. It appearing that the 

Motion was properly served upon all entities, that no objection was timely filed to the Motion, 

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and that good cause exists as set forth in the Motion, IT IS ORDERED, ADJUDGED AND 

DECREED THAT

1. The Motion is hereby granted.

2. Within 15 days of the entry of this Order, the Examinees shall produce the 

documents set forth on Schedule I attached hereto.

3. Upon request from the Creditor, the Debtor, Mrs. Bhat and R. Bhat shall submit to 

an examination by the Creditor at a time and place to be agreed upon, but which examination 

shall occur no later than June 14, 2019.

4. All documentary evidence shall be produced at Kutak Rock LLP, 901 East Byrd 

Street, Suite 1000, Richmond, VA 23219.

5. The Creditor, in its discretion, is authorized to issue subpoena duces tecums in 

furtherance of the relief provided for herein.

6. The Clerk shall serve copies of this Order to those parties not receiving service 

via CM/ECF.

ENTERED: ____________

UNITED STATES BANKRUPTCY COURT JUDGE

Order submitted by:

/s/ Jeremy S. Williams 

KUTAK ROCK LLP

Jeremy S. Williams (VSB No. 77469)

901 East Byrd Street, Suite 1000

Richmond, VA 23219-3500

Telephone: (804) 644-1700 

jeremy.williams@kutakrock.com

 Counsel to RREF II BB 2014-I Acquisitions, LLC

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4818-0004-4948.3

CERTIFICATE OF SERVICE

Pursuant to the Local Rules of this Court, I hereby certify under penalty of perjury that a 

true and correct copy of the foregoing was served to all counsel of record via the Court’s ECF, 

certified mail and/or first-class mail, on April 19, 2019, as follows:

Debtor (by First-Class Mail):

Shridhar Bhat

6331 River Road

Henrico, VA 23229

Counsel (by CM/ECF):

David K. Spiro

Spiro & Browne

6802 Paragon Place, Ste. 410

Richmond, VA 23230

U.S. Trustee (by CM/ECF):

John P. Fitzgerald, III

Office of the U.S. Trustee

701 E. Broad Street, Ste. 4304

Richmond, VA 23219

By: /s/ Jeremy S. Williams

 Counsel

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4818-0004-4948.3

SCHEDULE I

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SHRIDHAR BHAT 

1. Your federal and state tax returns for gift and income taxes prepared for 2015, 

2016, 2017, and 2018, including any amendments, schedules and/or revisions made thereto.

2. All of your financial statements you have prepared or had prepared, regardless of 

whether they have been presented to any person, for the last four (4) years.

3. All documents evidencing your ownership of any interest in any corporation, 

partnership, limited liability company or trust for the last four (4) years.

4. All evidence of your ownership of any stocks, shares, bonds, certificates of 

deposit, annuities and any other securities for the last four (4) years.

5. All paychecks, pay stubs and other documents evidencing your current income 

and the sources thereof for the last four (4) years.

6. All documents that discuss, refer or relate to the value of any of your assets within 

the last four (4) years.

7. All documents that contain a listing of your assets within the last four (4) years.

8. Your insurance documents showing any listing, whether itemized or not, of 

insured assets.

9. All documents that discuss, refer or relate to any jewelry, furs, art objects, coin or 

stamp collections, household goods or household furnishings which you own or maintain an 

interest in.

10. All documents that discuss, refer or relate to any annuities or life insurance 

policies you own or of which you are the beneficiary.

11. Any documents that discuss, refer or relate to any retirement plans you own or 

maintain an interest in, including without limitation, any IRA, ERISA, Keogh, or other pension 

or profit sharing plans.

12. All documents that reference any liabilities you owe to any person.

13. All documents that contain a listing of your liabilities.

14. All documents that discuss, refer or relate to any taxes of any kind owed by you to 

the Internal Revenue Service, the Commonwealth of Virginia, or any other taxing authorities.

15. All documents that discuss, refer or relate to any alimony, maintenance or support 

payments you owe to any person.

16. All documents consisting of credit card statements received by you within the last 

two (2) years.

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17. Your automobile, boat and aircraft title certificates.

18. Partnership agreements in which you are a partner.

19. Operating Agreements of limited liability companies in which you are a member.

20. Leases or assignments of leases in which you are a tenant or landlord.

21. Employment contracts, commission agreements, royalty agreements, and patents 

under which any sum of money is or may be payable to you for the last four (4) years.

22. Your general ledger, check register, bank deposit books or records, bank account 

statements and other related accounting information for every bank account in your name or in 

which you have an interest for the last four (4) years.

23. Check stubs, canceled checks, check books, and other records of withdrawals, 

having reference to any of your bank deposits and bank accounts for the last four (4) years.

24. Savings account books and records having reference to any of your savings 

accounts, savings and loan association accounts, postal savings accounts, credit unions, and other 

interest bearing deposits of money for the last four (4) years.

25. All documents that discuss, refer or relate to any of your brokerage accounts, 

including, without limitation, any brokerage account statements for the last four (4) years.

26. Your certificates of deposit and records of them for the last four (4) years.

27. Deeds to real property in which you have an interest for the last four (4) years.

28. Trust indentures, trust agreements, wills and other instruments evidencing or 

referring to any trust in which you have an interest for the last four (4) years.

29. Notes, drafts, bills of exchange, mortgages, checks and bonds in which you have 

an interest for the last four (4) years.

30. Patents, trademarks, copyrights, franchises and contracts in which you have an 

interest for the last four (4) years.

31. Powers of attorney, stock powers and other instruments whereby you, either alone 

or jointly with others, authorized any person, firm or corporation to handle any business or 

financial affairs for you for the last four (4) years.

32. Receipts and other evidences of payment of any note, mortgage, negotiable 

instrument, or other obligation in the amount of $250.00 or more for the last four (4) years.

33. Schedules of payments, showing payments made, on any note, mortgage, 

negotiable instrument, or other evidence of debt, for the last four (4) years.

34. Your safety deposit contracts for the last four (4) years.

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35. Any documents concerning accounts receivable which are payable to you for the 

last four (4) years.

36. Papers, documents, and instruments evidencing your ownership, equity, or 

participation in any type of business enterprise for the last four (4) years.

37. All documents relating to any divorce proceeding(s) to which you are, or have 

been, a party for the last four (4) years.

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LINDA LACOVA-BHAT 

Any and all documents related to your account with Union Bank & Trust from the date of 

opening until present, including, but not limited, copies of statements, items, memoranda, 

evidence of wire transfers, debits, credits, transfers and cashier’s checks, and as to any checks of 

any kind, copies of the front and back, and signature cards.

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4818-0004-4948.3

ROBERT LACOVA-BHAT

1. Your federal and state tax returns for gift and income taxes prepared for 2015, 

2016, 2017, and 2018, including any amendments, schedules and/or revisions made thereto.

2. All of your financial statements you have prepared or had prepared, regardless of 

whether they have been presented to any person, for the last four (4) years.

3. All documents evidencing your ownership of any interest in any corporation, 

partnership, limited liability company or trust for the last four (4) years.

4. All evidence of your ownership of any stocks, shares, bonds, certificates of 

deposit, annuities and any other securities for the last four (4) years.

5. All paychecks, pay stubs and other documents evidencing your current income 

and the sources thereof for the last four (4) years.

6. All documents that discuss, refer or relate to the value of any of your assets within 

the last four (4) years.

7. All documents that contain a listing of your assets within the last four (4) years.

8. Your insurance documents showing any listing, whether itemized or not, of 

insured assets.

9. All documents that discuss, refer or relate to any jewelry, furs, art objects, coin or 

stamp collections, household goods or household furnishings which you own or maintain an 

interest in.

10. All documents that discuss, refer or relate to any annuities or life insurance 

policies you own or of which you are the beneficiary.

11. Any documents that discuss, refer or relate to any retirement plans you own or 

maintain an interest in, including without limitation, any IRA, ERISA, Keogh, or other pension 

or profit sharing plans.

12. All documents that reference any liabilities you owe to any person.

13. All documents that contain a listing of your liabilities.

14. All documents that discuss, refer or relate to any taxes of any kind owed by you to 

the Internal Revenue Service, the Commonwealth of Virginia, or any other taxing authorities.

15. All documents that discuss, refer or relate to any alimony, maintenance or support 

payments you owe to any person.

16. All documents consisting of credit card statements received by you within the last 

two (2) years.

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4818-0004-4948.3

17. Your automobile, boat and aircraft title certificates.

18. Partnership agreements in which you are a partner.

19. Operating Agreements of limited liability companies in which you are a member.

20. Leases or assignments of leases in which you are a tenant or landlord.

21. Employment contracts, commission agreements, royalty agreements, and patents 

under which any sum of money is or may be payable to you for the last four (4) years.

22. Your general ledger, check register, bank deposit books or records, bank account 

statements and other related accounting information for every bank account in your name or in 

which you have an interest for the last four (4) years.

23. Check stubs, canceled checks, check books, and other records of withdrawals, 

having reference to any of your bank deposits and bank accounts for the last four (4) years.

24. Savings account books and records having reference to any of your savings 

accounts, savings and loan association accounts, postal savings accounts, credit unions, and other 

interest bearing deposits of money for the last four (4) years.

25. All documents that discuss, refer or relate to any of your brokerage accounts, 

including, without limitation, any brokerage account statements for the last four (4) years.

26. Your certificates of deposit and records of them for the last four (4) years.

27. Deeds to real property in which you have an interest for the last four (4) years.

28. Trust indentures, trust agreements, wills and other instruments evidencing or 

referring to any trust in which you have an interest for the last four (4) years.

29. Notes, drafts, bills of exchange, mortgages, checks and bonds in which you have 

an interest for the last four (4) years.

30. Patents, trademarks, copyrights, franchises and contracts in which you have an 

interest for the last four (4) years.

31. Powers of attorney, stock powers and other instruments whereby you, either alone 

or jointly with others, authorized any person, firm or corporation to handle any business or 

financial affairs for you for the last four (4) years.

32. Receipts and other evidences of payment of any note, mortgage, negotiable 

instrument, or other obligation in the amount of $250.00 or more for the last four (4) years.

33. Schedules of payments, showing payments made, on any note, mortgage, 

negotiable instrument, or other evidence of debt, for the last four (4) years.

34. Your safety deposit contracts for the last four (4) years.

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4818-0004-4948.3

35. Any documents concerning accounts receivable which are payable to you for the 

last four (4) years.

36. Papers, documents, and instruments evidencing your ownership, equity, or 

participation in any type of business enterprise for the last four (4) years.

37. All documents relating to any divorce proceeding(s) to which you are, or have 

been, a party for the last four (4) years.

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4818-0004-4948.3

CAPITAL ONE, N.A.

1. Loans by you under which any indebtedness has been owed on or after January 1, 

2009, where any of the obligors included:

a. Judgment Debtor.2

b. Any and all entities for which Judgment Debtor was a principal, manager, 

or member including, but not limited to, those referenced in Exhibit A.

c. Any individual or entity or trust for which Judgment Debtor had signature 

authority including, but not limited to, those referenced in Exhibit A.

d. Any individual or entity or trust over which Judgment Debtor exercised 

control including, but not limited to, those referenced in Exhibit A.

e. Any and all trusts for which Judgment Debtor was a trustee, trustor, 

settlor, beneficiary including, but not limited to, those referenced in Exhibit A.

The requested documents include, but are not limited to, loan applications, tax returns, 

financial statements and other papers reflecting the financial affairs of and assets owned by 

Judgment Debtor.

2. Deposit or brokerage accounts (including, but not limited to, copies of statements, 

items, memoranda, evidence of wire transfers, debits, credits, transfers and cashier’s checks, and 

as to any checks of any kind, copies of the front and back, and signature cards) maintained at you 

from and after January 1, 2009, by:

a. Judgment Debtor.

b. Any and all entities or trusts for which Judgment Debtor was a principal, 

manager, or member including, but not limited to, those referenced in Exhibit A.

c. Any individual or entity or trust for which Judgment Debtor had signature 

authority including, but not limited to, those referenced in Exhibit A.

d. Any individual or entity or trust over which Judgment Debtor exercised 

control including, but not limited to, those referenced in Exhibit A.

3. Communications (including, but not limited to, email correspondence, letters, 

facsimiles) maintained at you from and after January 1, 2009, by:

a. Judgment Debtor.

 

2

Judgment Debtor refers to: (i) Lacova-Bhat, L.C., (ii) Tanglewood Home for Adults, Inc., (iii) Alleghany Manor, 

LLC, (iv) Shridhar Bhat, individually, (v) Shridhar Bhat, Trustee of Irrevocable Trust FBO Robert L. Bhat Under 

Trust Agreement Dated January 20, 1997, (vi) Shridhar Bhat, Trustee of Irrevocable Trust FBO Nancy Bhat Under 

Trust Agreement Dated October 17, 2013, (vii) Shridhar Bhat, Trustee of Irrevocable Trust FBO Nancy Bhat.

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4818-0004-4948.3

b. Any and all entities or trusts for which Judgment Debtor was a principal, 

manager, or member including, but not limited to, those referenced in Exhibit A.

c. Any individual or entity or trust for which Judgment Debtor had signature 

authority including, but not limited to, those referenced in Exhibit A.

d. Any individual or entity or trust over which Judgment Debtor exercised 

control including, but not limited to, those referenced in Exhibit A.

Please produce in the first instance copies of statements for any accounts responsive to 

specification 2. Judgment creditor will review the statements and request specific items and 

other documents thereafter.

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4818-0004-4948.3

JPMORGAN CHASE & CO.

Any and all copies of statements, items, memoranda, evidence of wire transfers, 

payments, credits, transfers and cashier’s checks, and as to any check of any kind, copies of the 

front and back, and signatures from January 1, 2014 to the present for Account Nos. ending 2256 

and 5112.

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4818-0004-4948.3

PNC BANK, NATIONAL ASSOCIATION

All credit statements, memos, debit notices, checks, deposit slips and related materials 

regarding Account No. ending 1569, including copies, front and back, of any check of any kind.

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SUNTRUST BANKS, INC.

(1) All credit statements, memos, debit notices, checks, deposit slips and related materials 

regarding any and all deposits made to Account No. ending 8043; 

(2) Images of checks, both front and back, of any deposit or debit equal to or greater than $1,000 

regarding Account No. ending 8043

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4818-0004-4948.3

BRANCH BANKING AND TRUST COMPANY

Any and all copies of statements, items, memoranda, evidence of wire transfers, 

payments, credits, transfers and cashier’s checks, and as to any check of any kind, copies of the 

front and back, and signatures from January 1, 2014 to the present for Account No. ending 0862.

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4818-0004-4948.3

WELLS FARGO CLEARING SERVICES, LLC 

All credit statements, memos, debit notices, checks, deposit slips and related materials 

regarding all deposits into Account No. ending 2435.

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4818-0004-4948.3

WELLS FARGO BANK, N.A.

All credit statements, memos, debit notices, checks, deposit slips and related materials 

regarding all transactions greater than $4,000 for Account No. ending 6253.

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4818-0004-4948.3

ASBURY AUTOMOTIVE NORTH CAROLINA L.LC.

All documents and/or statements relating to any financial instruments or accounts 

in the name of and/or for the benefit of Lacova-Bhat, L.C., Tanglewood Home for Adults, 

Inc., Alleghany Manor, LLC, King Pin Investors, LLC, King Pin Properties, LLC, 

Shridhar V. Bhat Office of Physicians, Central Virginia Health Network, LC, Center for 

Internal Medicine, Hypertension & Kidney Disease, Inc., Shridhar Bhat, Linda LacovaBhat, Robert Lacova-Bhat, either individually or jointly or otherwise, from January 1, 

2014 to the present, including but not limited to the following documents:

(1) All statements;

(2) All financing documents, including but not limited to all loan request documents, 

commitment letters, credit reports, financial statements, and tax returns of all borrowers;

(3) Copies of the front and back of all checks, including all records showing the 

financial institution where any such check was deposited;

(4) Copies of all loan documents, including but not limited to all loan agreements, 

promissory notes, guaranties, notice of final agreement, disbursement authorizations, 

disbursement requests, and all other documents comprising any loan file;

(5) All communications between you and Shridhar Bhat, Linda Lacova-Bhat, Robert 

Lacova-Bhat, either individually or jointly;

(6) All contracts and/or agreements signed by Shridhar Bhat, Linda Lacova-Bhat, 

Robert Lacova-Bhat, either individually or jointly, including but not limited to new account 

forms and account opening documents;

(7) All documents relating to the net worth of Shridhar Bhat, Linda Lacova-Bhat, 

Robert Lacova-Bhat, either individually or jointly.

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4818-0004-4948.3

TRANSAMERICA LIFE INSURANCE

Any and all documents regarding, related to or referencing the assignment of policy no. 

ending 4003 to First Community Bank.

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4818-0004-4948.3

HARRIS, HARDY & JOHNSTONE, P.C.

All documents and/or statements relating to any financial instruments or accounts 

in the name of and/or for the benefit of Lacova-Bhat, L.C., Tanglewood Home for Adults, 

Inc., Alleghany Manor, LLC, King Pin Investors, LLC, King Pin Properties, LLC, 

Shridhar V. Bhat Office of Physicians, Central Virginia Health Network, LC, Center for 

Internal Medicine, Hypertension & Kidney Disease, Inc., Shridhar Bhat, Linda LacovaBhat, Robert Lacova-Bhat, either individually or jointly or otherwise, from January 1, 

2014 to the present, including but not limited to the following documents:

1. The Debtors federal and state tax returns for gift and income taxes prepared for 

the last four (4) years, including any amendments, schedules and/or revisions made thereto.

2. All of the Debtors financial statements, regardless of whether they have been 

presented to any person, in the last four (4) years.

3. All documents evidencing Debtors ownership of any interest in any corporation, 

partnership, limited liability company or trust.

4. All evidence of Debtors ownership of any stocks, shares, bonds, certificates of 

deposit, annuities and any other securities.

5. All paychecks, pay stubs and other documents evidencing Debtors current income 

and the sources thereof.

6. All documents that discuss, refer or relate to the value of any of the Debtors 

assets.

7. All documents that contain a listing of the Debtors assets.

8. Debtors insurance documents showing any listing, whether itemized or not, of 

insured assets.

9. All documents that discuss, refer or relate to any jewelry, furs, art objects, coin or 

stamp collections, household goods or household furnishings which Debtors own or maintain an 

interest in.

10. All documents that discuss, refer or relate to any annuities or life insurance 

policies Debtors own or of which Debtors are the beneficiary.

11. Any documents that discuss, refer or relate to any retirement plans Debtors own 

or maintain an interest in, including without limitation, any IRA, ERISA, Keogh, or other 

pension or profit sharing plans.

12. All documents that reference any liabilities Debtors owe to any person.

13. All documents that contain a listing of Debtors liabilities.

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4818-0004-4948.3

14. All documents that discuss, refer or relate to any taxes of any kind owed by the 

Debtors to the Internal Revenue Service, the Commonwealth of Virginia, or any other taxing 

authorities.

15. All documents that discuss, refer or relate to any alimony, maintenance or support 

payments Debtors owe to any person.

16. All documents consisting of credit card statements received by Debtors within the 

last two (2) years.

17. Debtors automobile, boat and aircraft title certificates.

18. Partnership agreements in which Debtors are a partner.

19. Operating Agreements of limited liability companies in which Debtors are a 

member.

20. Leases or assignments of leases in which Debtors are a tenant or landlord.

21. Employment contracts, commission agreements, royalty agreements, and patents 

under which any sum of money is or may be payable to Debtors.

22. Debtors general ledger, check register, bank deposit books or records, bank 

account statements and other related accounting information for every bank account in Debtors 

name or in which Debtors have an interest.

23. Check stubs, canceled checks, check books, and other records of withdrawals, 

having reference to any of Debtors bank deposits and bank accounts.

24. Savings account books and records having reference to any of Debtors savings 

accounts, savings and loan association accounts, postal savings accounts, credit unions, and other 

interest bearing deposits of money.

25. All documents that discuss, refer or relate to any of Debtors brokerage accounts, 

including, without limitation, any brokerage account statements.

26. Debtors certificates of deposit and records of them.

27. Deeds to real property in which Debtors have an interest.

28. Trust indentures, trust agreements, wills and other instruments evidencing or 

referring to any trust in which Debtors have an interest.

29. Notes, drafts, bills of exchange, mortgages, checks and bonds in which Debtors 

have an interest.

30. Patents, trademarks, copyrights, franchises and contracts in which Debtors have an 

interest.

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31. Powers of attorney, stock powers and other instruments whereby Debtors, either 

alone or jointly with others, authorized any person, firm or corporation to handle any business or 

financial affairs for them.

32. Receipts and other evidences of payment of any note, mortgage, negotiable 

instrument, or other obligation in the amount of $250.00 or more.

33. Schedules of payments, showing payments made, on any note, mortgage, 

negotiable instrument, or other evidence of debt, in the last four (4) years.

34. Debtors’ safety deposit contracts.

35. Any documents concerning accounts receivable which are payable to the Debtors.

36. Papers, documents, and instruments evidencing Debtors ownership, equity, or 

participation in any type of business enterprise.

37. All documents relating to any divorce proceeding(s) to which Debtors are, or have 

been, a party.

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4818-0004-4948.3

SENIOR’S FIRST CHOICE, INC., 

RICHMOND BEHAVIORAL HEALTH AUTHORITY 

CORRECTIONAL MEDICAL CARE, INC.

Any and all documents related to Dr. Shridhar V. Bhat, the Center for Internal Medicine, 

Hypertension, Kidney Disease & Critical Care, Inc., the Shridhar V. Bhat Office of Physicians or 

the Central Virginia Health Network, L.C., including, but not limited to, loan documents, checks, 

pay stubs and employment contracts

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4818-0004-4948.3

Schedule 1(A)

 Lacova-Bhat, L.C.

 Tanglewood Home for Adults, Inc. 

 Alleghany Manor, LLC 

 King Pin Investors, LLC 

 King Pin Properties, LLC

 Shridhar V. Bhat Office of Physicians 

 Central Virginia Health Network, L.C. 

 Center for Internal Medicine, Hypertension, Kidney Disease & Critical Care, Inc.

 Shridhar Bhat 

 Robert Lacova-Bhat 

 Linda Lacova-Bhat 

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