UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov 

In re: 

ROBERT W. SZOSTAK 

 Debtor. 

Chapter 7 

Case No. 22-11098-MAM 

 / 

NOTICE OF RULE 2004 EXAMINATION 

(Refiled After Reinstatement) 

 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 June 17, 2022 at 10:00 a.m.. The examination will be 

conducted via video conference [details will be filed on the docket the week 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 June 14, 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: May 31, 2022 

 REED SMITH LLP 

 /s/ Alexis A. Leventhal 

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

 Reed Smith LLP 

225 Fifth Avenue, Suite 1200 

Pittsburgh, PA 15222 

Case 22-11098-MAM Doc 44 Filed 05/31/22 Page 1 of 9
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 44 Filed 05/31/22 Page 2 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; 

Case 22-11098-MAM Doc 44 Filed 05/31/22 Page 3 of 9
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); 

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, 

Case 22-11098-MAM Doc 44 Filed 05/31/22 Page 4 of 9
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. 

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. 

Case 22-11098-MAM Doc 44 Filed 05/31/22 Page 5 of 9
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. 

2. The Debtor shall cooperate with the forensic firm by providing access 

to all Electronic Data Sources that may contain potentially relevant data. 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 

3. 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. 

4. 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. 

Case 22-11098-MAM Doc 44 Filed 05/31/22 Page 6 of 9
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 

Lead Hero 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 

Present Company LLC from February 1, 2018 to the present. 

7. 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. 

8. 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. 

9. Please produce any and all 1099s, W-2 or other statements of earnings 

from January 1, 2020 to the present from any sources for any wages, commissions 

bonuses, tips (including the dates earned) listed in Question 4 of the Statement of 

Financial Affairs filed by the Debtor in the above referenced case. 

10. Please produce any and all statements or other Documents from 

January 1, 2020 to the present from any sources for any Unemployment 

Compensation (including the dates paid and for what periods) listed in Question 5 

of the Statement of Financial Affairs filed by the Debtor in the above referenced 

case. 

Case 22-11098-MAM Doc 44 Filed 05/31/22 Page 7 of 9
11. Please produce any and all Documents from January 1, 2020 to the 

present for the “Attorney Fee” listed in Question 16 of the Statement of Financial 

Affairs filed by the Debtor in the above referenced case. 

 

Case 22-11098-MAM Doc 44 Filed 05/31/22 Page 8 of 9
CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that on May 31, 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 44 Filed 05/31/22 Page 9 of 9