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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

Miami Division

In re: Case No. 20-11043-RAM

GEORGE DE ARMAS, Chapter 13

Debtor.

______________________/

NOTICE OF 2004 EXAMINATION OF DEBTOR

NOTICE IS HEREBY GIVEN, that Casa Financial Holdings, LLC. as a Creditor of the 

Debtor, by and through its undersigned attorney, will be conducting examinations of:

NAME DATE & TIME

George De Armas March 20, 2020 at 10:00 A.M.1

at 150 West Flagler Street, Suite 1675, Miami, Florida 33130. This examination may 

continue from day to day until completed. If the examinee receives this Notice less than 

seven (14) days prior to the scheduled examination (or less than 10 days if the 

examination is taking place outside of Florida), the examination will be rescheduled upon 

timely request to a mutually agreeable time. The examination is pursuant to FRBP 2004 

and Local Rule 2004-1, and will be taken before an officer authorized to record the 

testimony. The scope of the examination shall be as described in FBRP 2004. Pursuant 

to Local Rule 2004-1, no order shall be necessary.

The Examinee is required to produce the documents requested on 

Schedule A on or before 5:00 p.m., March 11, 2020 at Roniel Rodriguez, 

IV, PA., 150 West Flagler Street, Suite 1675, Miami, FL 33130. 

I HEREBY CERTIFY that I am admitted to the Bar of the United States 

Bankruptcy Court for the Southern District of Florida, and that I am in compliance with the 

additional qualifications to practice in this Court set forth in Local Rule 2090-1(A) and that 

a true and correct copy of the foregoing was furnished by United States mail to all parties 

1

 To the extent that the Debtor or her counsel will not be unavailable at the scheduled and time, the examination 

will be rescheduled to a mutually convenient date and time. 

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on the attached Service List and electronically filed with the Clerk of Court by using the 

CM/ECF system which will send a notice of electronic filing to all parties and counsel 

identified on the CM/ECF service list maintained by the Court in this case on February 

21, 2020.

Respectfully submitted,

RONIEL RODRIGUEZ, IV, P.A.

Counsel for Creditor

12555 Biscayne Boulevard, #915, 

North Miami, FL 33181

Phone: 305-773-4875

Fax: 305-359-5196 

Email: Ron@RJRfirm.com

 /s/ Roniel Rodriguez, IV 

 RONIEL RODRIGUEZ IV 

Fla. Bar No.: 544787

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SCHEDULE “A” DEFINITIONS

1. “Bankruptcy Case” means this Chapter 13 bankruptcy case styled In re 

George De Armas, Case No. 20-11043 BKC-RAM. 

2. “Bankruptcy Code” means the United States Bankruptcy Code, 11 U.S.C. 

§§ 101 et seq., as amended. 

3. “Bankruptcy Court” means the United States Bankruptcy Court for the 

Southern District of Florida. 

4. “Communications” means any transmittal of information by any means or 

any response thereto by any means. 

5. “Concerning” means, directly or indirectly, in whole or in part, containing, 

constituting, contradicting, controverting, corroborating, demonstrating, 

describing, discussing, disputing, embodying, evidencing, identifying, 

memorializing, mentioning, pertaining to, proving, rebutting, recording, 

refuting, referring to, reflecting, relating to, showing, substantiating, 

summarizing, supporting, arising out of or in connection with, or in any way 

legally, logically, or factually connected with. 

6. “Debtor” means Beatriz Baldan. 

7. “Document” means any writing, recording, electronically stored 

information, photograph, or other tangible or intangible thing from which 

information may be obtained or derived, including, without limitation: original 

or exact copies of any tangible written, typed, printed, electronic, 

photographed, or other form of recorded or graphic matter of every kind or 

description, however produced or reproduced, whether mechanically or 

electronically recorded, draft, final, original, reproduction, signed or 

unsigned, regardless of whether approved, signed, sent, received, redrafted, 

or executed, and whether handwritten, typed, printed, photostatted, 

duplicated, carbon or otherwise copied or produced in any other manner 

whatsoever. Without limiting the generality of the foregoing, “document” shall 

include communications, correspondence, letters, telegrams, telexes, 

mailgrams, e-mails, text messages, instant messaging records or logs, 

calendars, diaries, memoranda (including interoffice memoranda, intraoffice 

memoranda, memoranda for files, and memoranda of telephone, meeting, 

or other conversations), notes or notations, minutes, booklets, books, 

drawings, graphs, charts, telephone records, telephone messages, 

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voicemail messages, video cassettes, electronic tapes, microfilms, discs or 

other recordings, computer programs, printouts, data cards, studies, analysis 

and other data compilations from which information can be obtained. Copies 

of documents which are not identical duplications of the original, or which 

contain additions to or deletions from the originals, or copies of documents 

which are identical duplications of the originals if the originals are not 

available, shall be considered to be separate documents. The term also 

refers to and includes all metadata associated with the subject document. 

8. “Person” means the singular or plural natural person, corporation, 

partnership, association, organization, government (including all 

instrumentalities, officers, agents, and subdivisions thereof), and all other 

business, legal, or artificial entities. 

9. “Petition Date” means January 27, 2020. 

10. “Request” means a request contained in the SPECIFIC REQUESTS 

section, infra. 

11. “You” or “Your” means Debtor. 

12. “Debtor Entities” means any entity which the Debtor acted as an officer, 

director, manager, shareholder, owner, or otherwise claimed an ownership 

interest in from January 1, 2014 through the date of production and includes, 

but is not limited to: Saga Bay SW 78th Place, LLC., Barbarosa Consulting 

Services, Inc., 3CI, LLC., GDA 2015, LLC.

INSTRUCTIONS 

1. The documents covered by the Requests include all documents in your 

possession, custody, or control, regardless of whether such documents or 

materials are possessed directly by you or your professionals, advisors, 

directors, officers, partners, associates, subsidiaries, affiliates, successors, 

accountants, investigators, managers, members, shareholders, 

representatives, employees, attorneys, agents, third party cloud providers, 

and any other persons or entities acting on your behalf or under your control. 

2. Each Request shall be deemed to be continuing in nature. If at any time 

additional documents come into your possession, custody, or control or are 

brought to your attention, prompt supplementation of your response to the 

Requests is required. 

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3. Documents shall be produced in the manner in which they are maintained 

in the usual course of the business. The documents shall be organized and 

labeled to correspond with the categories in the Requests. Each Request for 

a document shall be deemed to include a request for any and all file folders 

within which the document was contained, transmittal sheets, cover letters, 

exhibits, enclosures, or attachments to the document, in addition to the 

document itself. 

4. Documents shall be produced in such fashion as to identify the 

department, branch, or office in which they were located and, where 

applicable, the natural person in whose possession it was found and the 

business address of each document’s custodian(s). Each page produced in 

response to these Requests shall be stamped with a unique prefix, or 

otherwise identified, such that the source of each page or document 

produced is apparent. At a minimum, the entity producing the document shall 

be apparent. 

5. As to any document requested but withheld based on your assertion of 

any privilege or immunity, please set forth: (i) the title of the document; (ii) 

the type of document (e.g., letter, note, memorandum, etc.); (iii) the date of 

the document; (iv) the subject matter of the document; (v) the identities of all 

persons who authored the document, or assisted in its preparation, or in 

whose name the document was prepared; (vi) the identities of all persons to 

whom the document was addressed; (vii) the identities of all other persons 

to whom the document was sent, or who received, have seen, have had 

possession or custody of, or have had disclosed to them the contents of, the 

document or any copies thereof; and (viii) sufficient information regarding the 

grounds for withholding the document to explain the claim of privilege or 

immunity. 

6. If any document requested herein has been destroyed or lost, provide in 

lieu of the true and correct copy thereof a description of the document so lost 

or destroyed, together with the following information: (i) the date of the 

document; (ii) a brief description of the document; (iii) the author of the 

document; (iv) the date upon which the document was destroyed or lost; and 

(v) a brief statement regarding the manner in which the document was lost 

or destroyed. 

7. Documents attached to each other shall not be separated. 

8. Any word written herein in the singular shall be construed as plural or 

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vice versa as necessary in order to bring within the scope of the Request 

all documents that might otherwise be construed to be outside its scope. 

9. The terms “and” as well as “or” shall be construed disjunctively or 

conjunctively as necessary to bring within the scope of the Request all 

documents that might otherwise be construed to be outside its scope. 

10. The terms “all” and “each” shall be construed as “all and each.” 

11. If any copy of any document for which production is sought, whether a 

draft or a final version, is not identical to any other copy thereof, by reason 

of alterations, notes, comments, initials, underscoring, indication of routing 

or other material contained thereon or attached thereto, such non-identical 

copy shall be produced separately. 

12. If you consider any term in any Request to be vague or capable of more 

than one meaning, identify the meaning you are ascribing to such term, then 

respond to the Request as construed with such word given such meaning. 

13. Each Request shall be construed independently. No Request should be 

construed by reference to any other Request for the purpose of limiting the 

scope of response to such Request unless stated otherwise. 

RELEVANT TIME PERIOD

Unless otherwise stated, the “Relevant Time Period” for the Requests is 

January 2016 through the Petition Date. 

ELECTRONICALLY STORED INFORMATION

The Requests call for the production of electronically stored information 

(“ESI”) and ESI shall be produced in native form. In searching for electronic 

documents responsive to these Requests, you shall search for all such 

electronic documents regardless of the form in which the document exists or 

the location in which it is stored. Among other places, you shall search for 

electronic documents stored on all servers, networks, hard drives, desktop 

computers, notebook computers, personal digital devices, all back-up 

storage tapes, and with any third party cloud providers. 

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SPECIFIC REQUESTS

Please produce the following documents for the Relevant Time Period: 

A. BANK RECORDS 

1. Any and all documents and records of checking, savings, or any other type 

of account, foreign or domestic, maintained by You with any type of financial 

institution from January 2016 to present, including but not limited to monthly 

account statements, checks, check registers, check stubs, canceled checks, 

and deposit slips. 

2. Any and all documents that evidence, refer or relate to any transfers made 

to or from any financial account held for the benefit of You, by any third party, 

from January 2016 to present. 

3. Any and all signature cards that name You as an authorized signatory on 

any financial account, for any entity or other third party, from January 2016

to present. 

4. Any and all documents submitted to any bank, financial institution, or any 

other person or entity, by You, for any loan or advance, in any capacity 

(borrower, guarantor, or surety) from January 2016 to present. 

5. Any and all documents that evidence, refer or relate to any interest in, or 

claimed title to, any certificates of deposit, letters of credit, money orders, 

cashier’s checks, traveler’s checks, bank deposits, or escrow funds owned 

or held by You from January 2016 to present. 

6. Any and all documents that evidence, refer or relate to any account into 

which any of Your earnings or other income has been deposited from 

January 2016 to present, whether You continue to have an interest in it or 

not. 

7. Any and all documents that evidence, refer or relate to You having 

authority to access any safe-deposit box or other bank-secured area, from 

January 2016 to present. 

8. Any and all documents that evidence, refer or relate to any application 

signed by You or on Your behalf or on Your wife’s behalf and/or Your 

children’s behalf, to open a foreign or offshore financial account in Your

name or in the name of an entity. 

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B. REAL PROPERTY 

9. Any and all documents that evidence, refer or relate to any real property 

owned by You from January 2010 to present. 

10. Any and all documents that evidence, refer or relate to encumbrances on 

any real property owned by You from January 2010 to present. 

11. Any and all documents that evidence, refer or relate to ownership of real 

property in which You currently enjoy a direct or indirect beneficial interest. 

12. Any and all documents that evidence, refer or relate to the sale or transfer 

of any real property in which You had a legal or equitable ownership interest 

from January 2010 to present. 

13. Any and all lease agreements for real property in which You are the 

lessor or lessee. 

14. Any and all documents that evidence, refer or relate to Your name being 

on any real property tax records, as payor or trustee, from January 2010 to 

present. 

15. Any and all deeds that title any real property to You as trustee for any 

other person or entity. 

16. Any and all deeds of trust or mortgages held in favor of You at present 

or owned from January 2010 to present. 

17. Any and all documents that evidence, refer or relate to any time-share 

property that You enjoy the use of. 

18. Any and all documents that evidence, refer or relate to appraisals or other 

forms of valuation for any property that You have an interest in or held any 

interest from January 2010 to present. 

19. Any and all promissory notes or mortgages that You signed from January 

2010 to present. 

20. Copies of all deeds and mortgages to which You hold property as tenant 

by the entireties, tenant in common, or joint tenant from January 2010 to 

present. 

21. Any and all documents not otherwise herein requested, including but 

not limited to, leases, rental records, receipts and disbursements for the 

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following real property located at:

A. 200 East 27th Street, new York, NY; 

B. 2451 Brickell Avenue, Miami, Florida;

C. 20279 Old Cutler Road, Cutler Bay, Florida;

D. 407 Alcazar Avenue, Coral Gables, Florida

C. PERSONAL PROPERTY 

22. Copies of all certificates of title or other evidence of ownership of any 

boat, watercraft, motorcycle, four-wheeler, recreational vehicle, go-kart, 

aircraft, agricultural equipment, or construction equipment owned by or in 

possession of You, whether owned by You or an entity that You are affiliated 

with, or held in trust by You, from January 2016 to present. 

23. Any and all note receivables, pledges, or security interests in favor of 

You from January 2016 to present. 

24. Copies of all homeowner’s insurance policies and any other insurance 

policies or riders that have insured any property that You own or have the 

benefit of use of, from January 2010 to present. 

25. Any and all documents that evidence, refer or relate to household 

furnishings and fixtures that have been purchased by You from January 2016

to present that had a purchase price of $999 or more. 

26. Copies of all dock slips or other documentation evidencing the right to 

dock any watercraft in which You have a legal or beneficial interest from 

January 2016 to present. 

27. Any and all documents that evidence, refer or relate to any animals in 

which You have any ownership interest from January 2016 to present. 

28. Any and all documents that evidence, refer or relate to collectibles (e.g., 

stamps, coins, sports cards, etc.) that You now own or have owned from 

January 2016 to present. 

29. Any and all documents that evidence, refer or relate to any guns, jewelry, 

antiques, art, paintings, or other similar assets owned by You or in Your 

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possession from January 2016 to present. 

30. Any and all documents that evidence, refer or relate to any interest You 

have in any patents, trademarks, copyrights, franchises, royalties of any 

kind, oil and gas rights, timber rights, or mineral rights from January 2016 to 

present. 

31. Any and all documents that evidence, refer or relate to any cash which 

You held on Your own behalf or on behalf of any third-party, including without 

limitation any family members, from January 2016 to present. 

32. Any and all documents reflecting any losses resulting from gambling, 

gaming or other betting or wagering in any respect from January 2016 to 

present. 

D. BUSINESS INTERESTS/EMPLOYMENT 

33. Any and all documents that evidence, refer or relate to any agreement 

relating to compensation. 

34. Any and all documents that contain the terms of any arrangement 

between You and any person or entity under which You agreed to provided 

services for compensation from January 2016 to present. 

35. Any and all documents that identify any person or entity for whom You 

have acted as independent contractor from January 2016 to present. 

36. Any and all documents that evidence, refer or relate to Your ownership 

interest in any business entity, including without limitation, a corporation, a 

limited liability company, a partnership, a limited partnership, a limited liability 

partnership, a limited liability limited partnership, a professional association 

and a professional corporation. 

37. Four years of tax returns and financial statements for all entities in which 

You own a business interest. 

38. Any and all documents that evidence, refer or relate to Your resignation, 

termination or cessation from Your position as a stockholder, partner, officer, 

director, manager, member, owner, or registered agent of any business from 

January 2016 to present. 

39. Any and all corporate charters, minutes of stockholders’ meetings, 

resolutions, or recorded evidence of any kind relating to the affairs of any 

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corporation owned by You, or any subsidiary or other entity in which that 

corporation has held an ownership interest from January 2016 to present. 

40. All local, state, and federal tax returns filed by You from January 2016 to 

present, including all attachments, schedules, W-2’s, K-1’s, and 1099 and 

1098 forms. 

41. All W-4 tax withholding forms from January 2016 to present. 

42. Any and all documents that evidence, refer or relate to any records of 

salaries, commissions, bonuses, income from employment, wages, pay 

stubs, dividends, royalties, allowances, expenses, or other sums of money 

paid to You from January 2016 to present. 

43. Any and all employment contracts that You have had from January 2016

to present. 

E. INVESTMENTS 

44. Any and all documents that evidence, refer or relate to stocks, bonds, 

mutual funds, debentures, certificates of deposit, or other investment vehicle 

owned by You or held for Your benefit. 

45. Any and all documents that evidence, refer or relate to any retirement 

accounts or annuities, whether individual or employer sponsored, owned by 

You or held for Your benefit. 

46. Any and all rent rolls for the properties in which You have had an 

ownership interest from January 2016 to present. 

47. Copies of all 1099-DIV or 1099-INT forms issued to You from January 

2016 to present. 

48. Any and all documents that evidence, refer or relate to any stock options 

or profit- sharing plans held by You or for Your benefit. 

49. Any and all documents that evidence, refer or relate to a cash value in 

any life insurance policy of You and copies of all policies, whether term, 

whole life, or universal. 

50. Any and all documents that evidence, refer or relate to any 401K Plan in 

which You have an ownership interest. 

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F. GENERAL 

51. Any and all documents that evidence, refer or relate to any trust or 

amendments to trust in which You are a settlor, trustee, or beneficiary. 

52. Any and all documents that evidence, refer or relate to any trust or 

amendments to trust that You have directly or indirectly contributed from 

January 2016 to present. 

53. Copies of all prenuptial and postnuptial agreements, include the list of 

assets and liabilities to be held separately. 

54. Copies of all separate property agreements, include the list of assets and 

liabilities to be held separately. 

55. Copies of all wills, including all amendments, in which You are or were 

named as a beneficiary. 

56. Copies of any and all credit card statements for all cards on which You 

are an authorized user from January 2016 to present. 

57. Any and all document that evidence, refer or relate to any storage facility 

or mini- warehouse, self storage space or similar real property designed and 

used for the purpose of renting or leasing individual storage spaces for the 

purpose of storing and removing personal property to which You have 

access. 

58. Copies of any and all financial statements that You have prepared for 

any lender, creditor, or third party from January 2016 to present. 

59. Copies of any and all professional licenses held by You. 

60. Copies of all of Your driver’s licenses. 

61. Copies of all judgments of dissolution of marriage and any affidavits 

submitted in those proceedings. 

62. Copies of all transcripts of any depositions in at which You testified from 

January 2016 to present. 

63. Any and all documents that evidence, refer or relate to money owed to 

You by any individual or entity for which the obligation remains unpaid. 

64. Any and all receipts or other documents You received from any third party 

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for donations of any money or property from January 2016 to present. 

65. Your will or any other estate planning documents. 

66. Copies of any documents related to any arrest or conviction for criminal 

activity.

67. Copies of any leases where you are identified as a landlord, tenant,

guarantor, or occupant from 2016 through the date of production.

68. Any and all documents related to compensation or payments received 

by You from the Debtor Entitties for the past five (5) years.

69. Any and all documents which evidence travel outside the State of Florida 

from 2016 through the date of production.

70. Copies of all of Your passports that have been valid for the past five (5) 

years.

71. Copies of any and documents which evidence any payments made to 

an attorney for the past five (5) years.

72. Copies of any and all documents evidencing any agreements with any of 

the Debtor Entitities.

73. Copies of any and all documents not otherwise herein produced related 

to the Debtor Entitites.

74. Copy of Your marriage license. 

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