UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flmb.uscourts.gov

In re:

ROBERT W. SZOSTAK

Debtor.

Chapter 7

Case No. 22-11098-MAM

/

NOTICE OF RULE 2004 EXAMINATION

Testimony: Pursuant to Federal Rule of Bankruptcy Procedure 2004 and Local Rule 

2004-1, MicroBilt Corporation and Princeton Alternative Funding, LLC will examine Robert 

Szoztak, the Debtor under oath on March 30, 2022 at 10:00 a.m.. (ET) The examination will be 

conducted via video conference (details will be filed on the docket and served five (5) days

before the examination), and will be recorded stenographically by a court reporter, who shall be 

available at the scheduled time and place, and further intends to use real-time transcription if 

available. The examination may continue from day to day until completed. 

Production: Pursuant to Federal Rule of Bankruptcy Procedure 2004 and Local 

Rule 2004-1, MicroBilt Corporation and Princeton Alternative Funding, LLC requests that 

Robert Szostak the Debtor produce the documents, electronically stored information, or objects 

described on the attached schedule (or if the examination is of a witness other than the debtor, on 

the attached subpoena), who must permit inspection, copying, testing, or sampling of the materials

on March 23, 2022 at 9:00 a.m. (prevailing eastern time), at 777 S Flagler Dr ., West Palm 

Beach FL 33401

If the examinee receives this notice less than 14 days before the scheduled examination 

date, the examination will be rescheduled upon timely request to a mutually agreeable time. The 

scope of the examination will be as described in Bankruptcy Rule 2004. Pursuant to Local Rule 

2004-1 no order is necessary. If the examination is of a witness other than the debtor, the Local 

Form “Subpoena for Rule 2004 Examination” is included with this notice.

Dated: March 7, 2022

REED SMITH LLP

/s/ Alexis A. Leventhal

Alexis A. Leventhal (Fla. Bar No. 108064)

225 Fifth Avenue, Suite 1200

Pittsburgh, PA 15222

Telephone: (412) 288-3131

Facsimile: (412) 288-3063

Email: aleventhal@reedsmith.com

Counsel for MicroBilt Corporation and Princeton 

Alternative Funding, LLC

Case 22-11098-MAM Doc 20 Filed 03/07/22 Page 1 of 9
SCHEDULE TO NOTICE OF RULE 2004 EXAMINATION

PRIVILEGED OR PROPRIETARY MATTERS

If any document request requires the production of documents for which the protection of 

privilege or work product is asserted, identify in writing each document and provide the following 

information:

(a) the reason for withholding the document;

(b) a statement of the basis for the claim of the privilege, work product, 

or other grounds of nondisclosure; and

(c) a brief description of the document, including:

(i) the date of the document;

(ii) number of pages, attachments, and appendices;

(iii) the names of its author, authors, or preparer and 

identification by employment and title of each such person;

(iv) the name of each person who was sent, shown, or carbon 

copied the document or who has had access to or custody of the 

document, together with an identification of each such person;

(v) the present custodian; and

(vi) the subject matter of the document, and in the case of any 

document relating or referring to a meeting or conversation, 

identification of such meeting or conversation.

LOST OR DESTROYED DOCUMENTS

If any document requested has been lost, discarded, or destroyed, identify such document 

as completely as possible, including the following information:

a. the type of document;

b. the date of the document;

c. the date or approximate date it was lost, discarded, or destroyed;

d. the circumstances and manner in which it was lost, discarded, or 

destroyed;

e. the reason or reasons for disposing of the document (if discarded or 

destroyed);

Case 22-11098-MAM Doc 20 Filed 03/07/22 Page 2 of 9
f. the identity of all persons authorizing or having knowledge of the 

circumstances surrounding disposal of the document;

g. the identity of the person(s) who lost, discarded, or destroyed the 

document; and

h. the identity of all persons having knowledge of the contents thereof.

TIME PERIOD FOR REQUESTED DOCUMENTS

Except as provided in a particular document request, you shall produce all documents 

created, revised, or amended from and including November 1, 2014 to present. 

DEFINITIONS

1. “concerning” means relating to, referring to, describing, evidencing or 

constituting.

2. “communication” means the transmittal of information (in the form of facts, 

ideas, inquiries or otherwise).

3. “document” means all written, graphic, or otherwise recorded matter, however 

produced or reproduced, in the actual or constructive possession, custody, care or control of 

Debtor, Debtor’s agents and attorneys, or any of them, including but not limited to, originals and 

all copies of correspondence, tapes, videotapes, disks, notes, photographs, sound recordings, 

memoranda of all types, reports, copies of tax returns and records, receipts, bills, invoices, 

purchase orders, charge slips, hotel charges, working papers, computer printouts, charts, 

statistical records, delivery records, stenographers' notebooks, desk calendars, appointment 

books, diaries, time sheets and logs, job, matter and transaction files, and any papers or 

recordings similar thereto, including, without limitation, electronic or computerized data 

compilations. A draft or non-identical copy is a separate document within the meaning of this 

term.

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4. “Debtor” means Robert Szostak and representatives of any of the foregoing and 

all other persons acting or purporting to act on behalf of any of the foregoing.

5. “Electronic Data Sources” means your computers, cell phones, laptops, personal 

devices, servers, drives and any other storage devices that contain relevant information as 

described below

• e-mail, voice mail, text, WHATS APP and other instant messaging applications;

• Word or WordPerfect digital documents and drafts;

• Excel or other spreadsheets and tables;

• Accounting Application Data;

• Facsimile and PDF, TIFF, JPG, images;

• Video, Audio Photographs and AVI files;

• Databases;

• Outlook or other contact and relationship management data;

• Outlook and other calendar and diary application data;

• Online Access Data;

• PowerPoint and other presentations;

• Network Access and Server Activity Logs;

• Project Management Application Data;

• Computer Aided Design/Drawing Files;

• Back Up and Archival Files; and

• Social Media applications and websites, including, but without limitation, 

Facebook, Twitter, LinkedIn, blogs.

6. “person” means any natural person or any business, legal or governmental entity 

or association.

7. “Relevant Time Period” means the period of time commencing on November 1, 

2014 and ending on the date of the deposition held pursuant to this Notice.

8. “you” or “your” means the party to whom this Notice is addressed, together with 

all agents and other persons acting on behalf of that party.

INSTRUCTIONS

1. The Debtor shall produce the Electronic Data Sources for a forensically sound 

inspection and collection by a forensic firm. 

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2. The forensically sound collection and subsequent searching and production of 

relevant information and documents shall be handled in accordance with Appendix A to the 

Court’s December 17, 2021 Order entered in the case captioned Princeton Alternative Funding, 

LLC v. Farrell, et al. MER-L-000675-20/MER C-6-16 (N.J. Super. Ct. Law Div.) and attached 

and incorporated herein.

3. The Debtor shall cooperate with the forensic firm by providing access to all 

Electronic Data Sources that may contain potentially relevant data, including but not limited to 

any and all Electronic Data Sources referenced in the Electronically Stored Information 

Preservation Letter dated September 30, 2021 which is attached hereto and incorporated herein. 

Access to all electronic data sources will include, but is not limited to, providing log in 

credentials, passwords and requisite access to the data sources.

Requests for the Production of Documents

1. Please produce a copy of the Certificate of Completion in Part 5, Question 15 of 

the Petition filed by the Debtor. 

2. Please produce any and all statements of account or transactions history from 

February 1, 2021 to the present for any accounts listed in Part 4, Question 17 of the Schedule 

A/B filed by the Debtor in the above referenced case.

3. Please produce any and all Documents exchanged and/or communications with 

the Securities and Exchange Commission related to the “Possible SEC Whistleblower Award” 

listed in Part 4, Question 34 of the Schedule A/B filed by the Debtor in the above referenced 

case.

4. Please produce all Documents in any way related to any aspect of the Debtor’s 

association with or ownership, founding and officer/manager role with Lead Hero LLC from 

February 1, 2018 to the present. 

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5. Please produce all Documents in any way related to any aspect of the Debtor’s 

association with or ownership, founding and officer/manager role with Present Company LLC 

from February 1, 2018 to the present. 

6. Please produce all Documents in any way related to any aspect of the Debtor’s 

association with or ownership, founding and officer/manager role with Sarah Copley Media from 

February 1, 2018 to the present. 

7. Please produce any and all statements of account or transactions history from 

February 1, 2021 to the present for any accounts listed in Part 2, Question 4 of the Schedule E/F 

filed by the Debtor in the above referenced case. 

8. Please produce any and all Documents and materials required by the Court’s 

December 17, 2021 Order and the Court’s February 4, 2022 Order entered in the case captioned 

Princeton Alternative Funding, LLC v. Farrell, et al. MER-L-000675-20/MER C-6-16 (N.J. 

Super. Ct. Law Div.) 

9. As required by the Court’s December 17, 2021 Order and the Court’s February 4, 

2022 Order entered in the case captioned Princeton Alternative Funding, LLC v. Farrell, et al. 

MER-L-000675-20/MER C-6-16 (N.J. Super. Ct. Law Div.), please produce all of the Debtor’s 

electronic devices for forensic inspection and imaging.

10. As required by the Court’s December 17, 2021 Order and the Court’s February 4, 

2022 Order entered in the case captioned Princeton Alternative Funding, LLC v. Farrell, et al. 

MER-L-000675-20/MER C-6-16 (N.J. Super. Ct. Law Div.), please produce all of the Debtor’s 

Electronic Data Sources, including, but are not limited to, the following:

a. the Debtor’s personal Dell computer;

b. the Debtor’s cell phone (including, but not limited to those bearing 

numbers 609.306.7210 and/or 609.731.1474

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c. The Debtor’s personal email accounts (Bertstak@yahoo.com,

Bertstak@gmail.com, Bert@presentcompanyonline.com, Ben@keycap.com,

Bert@leadhero4sales.com, and Bert@crossbowcapitaladvisors.com) and 

including all inboxes, received items, all outboxes and sent items and all sent 

items, spam, deleted folders and calendar and contact information;

11. Please produce all e-mail and other written communications, memorandums, 

writings, excels, QuickBooks, and attachments by, between or among the Debtor to anyone, 

concerning any issues related to any aspect of the Debtor’s employment with, association with or 

ownership in Princeton Alternative Funding, LLC and/or Princeton Alternative Income Fund LP 

12. Please produce all text message communications on any cell phone, personal 

device or other electronic device used by Debtor, related to any aspect of the Debtor’s 

employment with, association with or ownership in Princeton Alternative Funding, LLC and/or 

Princeton Alternative Income Fund LP. 

13. Please produce all computer websites visited, computer searches on any and all 

search engines related to any aspect of the Debtor’s employment with, association with or 

ownership in Princeton Alternative Funding, LLC and/or Princeton Alternative Income Fund LP.

14. Please produce all voice mail communications related to any aspect of the 

Debtor’s employment with, association with or ownership in Princeton Alternative Funding, 

LLC and/or Princeton Alternative Income Fund LP

15. Please produce all video, sound recordings and photographs related to any aspect 

of the Debtor’s employment with, association with or ownership in Princeton Alternative

Funding, LLC and/or Princeton Alternative Income Fund LP.

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on March 7, 2022, a copy of the foregoing was electronically 

filed with the Court using the CM/ECF system, which sent notification to all parties of interest 

who are participating in the CM/ECF system, and by First Class U.S. mail to all parties on the 

attached mailing service list.

/s/ Alexis A. Leventhal

Alexis A. Leventhal

First Class U.S. Mailing List: 

Robert W. Szostak

3191 S Dixie Hwy, Apt 515

West Palm Beach, FL 33405-1596

Case 22-11098-MAM Doc 20 Filed 03/07/22 Page 8 of 9
APPENDIX A

1. Defendants shall select and engage a reputable forensic firm to conduct an inspection and 

collection of specified electronic data sources in a forensically sound manner from Defendants 

(collectively, the "Providing Parties"). 

2. Defendants shall cooperate with the forensic firm by providing access to all electronic data sources 

that may contain potentially relevant data, including but not limited to any and all electronic data 

sources referenced in the Plaintiff’s Electronically Stored Information Preservation Letter dated 

September 30, 2021. Access to all electronic data sources will include, but is not limited to, 

providing log in credentials, passwords and requisite access to the data sources. 

3. Plaintiff shall submit a list of proposed search terms to Defendants and both parties will meet and 

confer to finalize the targeted search terms to identify potentially relevant information contained 

on the identified electronic sources. The agreed-upon search terms will be applied to the collected 

electronic data by the independent forensic firm. Data that cannot be searched by the forensic 

collection firm during the collection process will be maintained by the collection firm. The 

collection forensic firm will then apply the agreed-upon search terms to the electronic data at its 

in-house facilities. 

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