UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

In re:

AUSTIN BRODE HOWARD,

 Debtor.

__________________________/

Case No.: 22-11866-LMI

Chapter 7

RE-NOTICE OF CONTINUED RULE 2004 EXAMINATION DUCES TECUM

OF DEBTOR AUSTIN BRODE HOWARD

(Date change)

MARCIA T. DUNN, as Chapter 7 Trustee (the “Trustee”) for the bankruptcy estate of 

AUSTIN BRODE HOWARD (the “Debtor”), by and through her undersigned counsel, pursuant 

to Fed.R.Bankr.P. 2004 and Local Rule 2004-1, will continue the examination of the following 

examinee (the “Examinee”):

Examinee Date/Time Location

Austin Brode Howard July 7, 2022

at 10:00 a.m. (Eastern)

c/o Dunn Law, P.A.

66 West Flagler St., Suite 400

Miami, Florida 33130

Via Zoom

The examination was coordinated with Debtor’s counsel and is being conducted pursuant to 

Fed.R.Bankr.P. 2004 and Local Rule 2004-1. The scope of the examination shall be as described in 

Fed.R.Bankr.P. 2004. Pursuant to Local Rule 2004-1, no order or subpoena shall be necessary, and 

to the extent that a request for production of documents under this rule may be construed as a 

request under Bankruptcy Rule 7034, the time to respond is shortened to fourteen (14) days.

This is a remote deposition; please do not come to our offices. The examination will be 

taken stenographically, via Zoom Video Conferencing or other approved electronic/remote platform. 

Examinee’s counsel will be provided with a Zoom link in advance of the deposition.

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The examination may continue from day to day until completed. If the Examinee receives 

this notice less than fourteen (14) days prior to the scheduled examination date, the examination will 

be rescheduled upon timely request to a mutually agreeable date and time.

If the Examinee requires an interpreter, it is Examinee’s responsibility to engage the 

employment of such interpreter to be present at the deposition.

The Examinee is further requested to electronically produce all pending documents described 

on the attached SCHEDULE “A” to undersigned counsel no later than June 24, 2022, to 

michael.dunn@dunnlawpa.com and rbasnueva@dunnlawpa.com. A Dropbox link has been

provided to Examinee’s counsel.

Respectfully submitted June 14, 2022.

CERTIFICATE OF SERVICE

I CERTIFY that a true and correct copy of the foregoing was served by U.S. mail on June 

14, 2022, upon the Debtor:

Austin Brode Howard

18117 Biscayne Blvd., Unit 2031

Aventura, FL 33160

I CERTIFY that a true and correct copy of the foregoing was served via Notice of 

Electronic Filing (CM/ECF) on June 14, 2022, upon all registered users in this case. 

DUNN LAW, P.A.

Counsel for Marcia T. Dunn, Trustee

66 West Flagler Street, Suite 400

Miami, Florida 33130

Tel: 786-433-3866

Fax: 786-260-0269

michael.dunn@dunnlawpa.com

By: /s/ Michael P. Dunn

Michael P. Dunn, Esq.

Florida Bar No. 100705 

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EXHIBIT “A”

DEFINITIONS

Unless the context of a specific request requires otherwise, the following definitions and 

instructions shall apply to these requests:

A. “Debtor”, “Examinee”, “You” and “Your” shall mean AUSTIN BRODE HOWARD.

B. “Petition Date” shall mean March 8, 2022.

C. “Case” or “instant cause” means the instant bankruptcy case, styled In re: Austin Brode 

Howard d/b/a The Motorcar Collection, LLC, d/b/a Optionguard LLC, d/b/a Collection Miami, LLC,

d/b/a The Motorcar Collection Miami Corp., d/b/a The Motorcar Collection Corp. (Case No.: 22-

11866-LMI), pending in the United States Bankruptcy Court, Southern District of Florida, Miami 

Division.

D. “Bank accounts” shall mean any checking, savings, certificates of deposit and other 

deposit accounts held by a financial institution, bank or credit union.

E. “Creditor” shall mean any person or entity to whom the Debtor owes money or is due 

performance of any other contractual obligation.

F. “Communication” or “Communications” includes every manner of transmitting or 

receiving facts, information, opinions or thoughts (including, but not limited to: visually; orally; in 

writing; by digital, analog, electronic, magnetic, telephonic, or other mechanical means; or otherwise), 

including, without limitation, oral conversations, telephone calls, written correspondence, memoranda 

or notes, meetings document transmittals, facsimiles, emails or any other method by which information 

is transmitted.

G. “Concerning”, “concern,” or any other derivative thereof, as used herein shall be 

construed as referring to, responding to, relating to (as defined herein), pertaining to, connected with, 

comprising, memorializing, commenting on, regarding, discussing, showing, describing, reflecting, 

analyzing or constituting.

H. “Contract” or “contracts” shall mean (a) an agreement, oral or written, between two or 

more Persons which creates an obligation to do or not to do a particular thing, and (b) any document 

which serves as proof of the obligation, including, without limitation, any subcontract, insurance policy 

or other formal agreement, including exhibits, attachments, amendments (whether with or without 

effect), modifications (whether with or without effect), and addenda.

I. “Coronavirus (COVID-19) Relief” shall mean the Payroll Protection Program known 

as PPP, Economic Injury Disaster Loans known as EIDL, the Families First Coronavirus Response Act 

known as FFCRA, U.S. Small Business Administration (known as the SBA) loans, and The 

Coronavirus Aid, Relief, and Economic Security Act known as the CARES Act.

J. “Document”, “documents”, or “documentation” means the original or a copy of any 

tangible thing from or on which Information can be stored, recorded, processed, transmitted, inscribed, 

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or memorialized in any way by any means, regardless of technology or form an including, but not 

being limited to: accounting books or records; accounts; account statements; affidavits; agendas; 

agreements; analyses; applications; appointment books; appraisals; audio tapes; balance sheets; 

bordereaux; books; books or records of account; brochures; cables; calendars; catalogues; CD-ROMs; 

certificates; charts; circulars; compact discs; computer printouts; contracts; correspondence; data 

processing input and output; deeds; deposition transcripts; desk calendars; diaries; digital images; 

drafts; DVDs; DVD-ROMs; electrical recordings; electronically stored Information, e-mail 

communications; evaluations; Excel spreadsheets; experiments; faxes; facsimiles; films; financial 

statements; floppy disks; guides; guidelines; hard copies of electronic, electrical, magnetic or any other 

communications not made on paper; hard disk drives; hearing transcripts; income statements; instant 

messages; interoffice communications; journals; ledgers; letters; lists; logs; magazines; magazine 

articles; magnetic recordings, magnetic tapes; manuals; memoranda; microfilms; minutes; newspapers, 

newspaper articles; notations, notebooks; notes; objects; opinions; papers; photographs; policies; 

PowerPoint presentations; procedures; profit and loss statements, prospectuses; receipts; recordings; 

releases; reports; schedules; signature cards; sound recordings; spreadsheets; statements; statements of 

cash flow; statistical records; stock certificates; summaries of accounts; summaries; tables; tabulations; 

tangible things; telecommunications; telegrams; telefaxes; telex messages; tests; text messages; titles; 

transcripts; videos; videotapes; websites; work papers; and any other writings, be they typewritten, 

handwritten, printed, stored in or on any form of electronic or magnetic media, or otherwise, and other 

records, recordings or pictures of any kind or description. Each copy of a document which contains 

any separate notations or writings thereon shall be deemed to be a separate document for purposes of 

these requests. Any document identified will include any document, in draft or final form, either sent 

or received by You. This term also includes any documents now or ever in Your possession, custody 

or control, or available to You, Your attorneys, accountants, agents, representatives, employees, or 

associates, and specifically includes documents kept by individuals in their desks, at home, or 

elsewhere. 

K. “Documents” shall also mean all electronic data storage documents or electronically 

stored information (“ESI”) including, but not limited to, e-mails and any related attachments, electronic 

files or other data compilations which relate to the categories of documents as requested below. Your 

search for these electronically stored documents shall include all of Your computer hard drives, floppy 

discs, compact discs, backup and archival tapes, removable media such as zip drives, password 

protected and encrypted files, databases, electronic calendars, personal digital assistants, proprietary 

software, and inactive or unused computer disc storage areas.

L. “Information” shall be expansively construed and shall include, but not be limited to 

facts, data, opinions, images, impressions, concepts and formulae.

M. “Person” means any natural person, firm, partnership, joint venture, corporation, or 

group of natural persons or such entities.

N. “Relating to,” “related” or “relating” means, directly or indirectly, refer to, mention, 

describe, pertain to, arise out of or in connection with or in any way legally, logically, or factually 

connected with the matter discussed.

O. When referring to a person, the term “Identify” shall mean to give, to the extent known, 

the person’s full name, present or last known address, present of last known telephone number, present 

or last known e-mail address, and when referring to a natural person, additionally, the present or last 

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known place of employment. Once a person has been identified in accordance with this paragraph, 

only the name of that person need be listed in response to subsequent discovery requesting the 

identification of that person.

P. When referring to a document, the term “Identify” shall mean to state the type of 

document as defined herein, the subject matter thereof, the date thereof, by whom it was written or 

prepared, by whom it was signed, to whom it was sent, the present location (name and address of place) 

thereof, and the present custodian of the original or copies thereof, so that the document is described 

in sufficient enough detail that it could be subject to a request for production of documents under the 

applicable rules of civil procedure. If any such document was, but no longer is, in Your possession or 

subject to Your control, state the disposition of the document.

Q. When referring to a communication other than a document, the term “Identify” shall 

mean to describe the communication in such a manner that all the following Information is provided: 

(1) whether the communication took place in person, by telephone, via e-mail, or otherwise; (2) if by 

telephone, the identity of the person originating the call, the identity of the person receiving the call, 

the identity of all other persons participating in the communication, and the location of each of those 

persons at the time of the communication; and the identity of all other persons present within hearing 

of any party to the communication; (3) if by e-mail, the identity, including name and e-mail address, 

of the person originating the e-mail; the identity or identities, including name and e-mail address, of 

all recipients; both intended and unintended, and including persons to whom blind copies were sent, 

of the e-mail communication; the date and time of the communication; all replies to and forwards of 

the original communication; the subject of the e-mail communication; and the identity and physical 

location of the computer, network, or server from which the e-mail was sent; (4) in in Person, the 

identity of all persons present during the communication and the location of the communication; (5) 

the date and time of the communication; (6) to the best of Your recollection, what was said by each 

party to the communication; and (7) the identity of the custodian of any document that recorded, 

summarized, or concerned the communication.

R. The connectives “and” and “or” shall be construed either disjunctively or conjunctively 

as necessary to bring within the scope of this discovery all responses that might otherwise be construed 

to be outside of its scope.

S. The words “any,” “all” and “each” shall be construed as necessary to bring within the 

scope of this discovery request all responses that might otherwise be construed to be outside of its 

scope.

T. The use of the singular form of any word includes the plural and vice versa.

U. The use of the masculine form of any word includes the feminine form and the neuter 

form, and vice versa.

INSTRUCTIONS

With respect to this request for documents, the following instructions shall apply:

A. This request for documents is continuing so as to require supplementary documents if 

additional information or documents hereafter are obtained or discovered which may augment or 

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otherwise modify the information that You provide and documents that You produce. Supplementary 

documents are to be served within five (5) days after receipt or discovery of such information or 

documents.

B. Examinee is hereby notified that its duty to respond to this document request includes the 

duty to furnish all information, documents and materials which are in Your possession or available to 

You, including all those which can be obtained from additional sources or in the possession of Your 

agents, representatives, employees, investigators, attorneys, or anyone acting on their behalf or on Your 

behalf, pursuant to Fed.R.Bankr.P. 7036. If You are unable to locate any requested information or 

document after exercising due diligence to secure the requested document, so state.

C. In the event that any document requested herein is not presently in Your possession or 

subject to Your control, please identify each person You have reason to believe had or has knowledge of 

its contents.

D. If any document is not produced under a claim of privilege, for each such document 

identify the nature of the privilege (including work product) that is being claimed, indicate the 

document request to which the document is responsive, and provide the following information, unless 

divulgence of such information would cause disclosure of the allegedly privileged information: (1) the 

type of document, including the number of pages, and attachments or appendices; (2) the general subject 

matter of the document; (3) the date of the document; (4) all persons to whom the document was 

distributed, shown or explained; and (5) such other information as is sufficient to identify the document 

for a subpoena duces tecum, including, where appropriate, the author of the document, the addressee 

of the document, and, where not apparent, the relationship of the author and the addressee to each 

other.

E. In the event that any document called for has been destroyed, discarded, or otherwise 

disposed of, identify the document by stating its: (a) author or preparer; (b) addressee(s); (c) indicated 

or blind copies; (d) date; (e) subject matter; (f) number of pages; (g) attachments or appendices; (h) all 

Persons to whom it was distributed to or shown; (i) date of destruction of other disposition; (j) manner 

of destruction or other disposition; (k) reason for destruction or other disposition; (l) Person destroying 

or disposing of the document; and (m) the document request or requests to which the document is 

responsive.

F. In producing documents requested herein, You shall produce documents in full, without 

abridgment, abbreviation, and expurgation of any sort.

G. To the extent this request seeks production of ESI residing elsewhere other than, or in 

addition to, on back-up copies, such information should be produced in its Native Format on hard drive or 

other digital storage media that does not otherwise detract from the original format of the files, or that by 

default may exclude or somehow later any metadata associated with said files. The information produced 

should include any original or existing full file path, file or fold structure, or other source referencing data, 

and be fully inclusive of all supporting and underlying data, the absence of which would render the 

information incomplete or unusable. For purposes of this Instruction, the term “Native Format” shall mean 

the format that the data was original created in. This should include, but not limited to, information about 

the software that the data was created in, stored in, or was used, or is used to read, write, alter, modify, or 

in any way change or manipulate the data. 

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H. All archived data being produced in response to this Request should be provided with the 

means to view and export such data. Paper documents that are not otherwise contained, stored, or 

recoverable by electronic means should be provided either in paper format, or via a scanned image in a 

.PDF or .TIFF format. Colored pages, photographs or other documents among such paper documents that 

would otherwise loose the color format should be scanned in.JPEG or other standard color format. 

I. All documents shall be produced as they are kept in the usual or ordinary course of 

business with any identifying labels, file markings or similar identifying features, and shall be organized 

and segregated in accordance with the numbered and lettered paragraphs and subparagraphs herein, 

pursuant to Fed.R.Civ.P. 45, made applicable in bankruptcy cases by Fed.R.Bankr.P. 9016.

J. All requests herein refer to the period from March 1, 2018, to the date of production, 

unless otherwise specifically indicated, and shall include all documents and information that relate to 

such period, even though prepared, generated or published prior to or subsequent to that period. 

K. The Examinee is requested to electronically produce all documents described on the 

attached Exhibit “A” on or before May 8, 2022, to michael.dunn@dunnlawpa.com and 

rbasnueva@dunnlawpa.com. A Dropbox link will be provided to Examinee’s counsel.

DOCUMENT REQUESTS

A. Real Property

1. All documents that evidence, refer or relate to any real property owned or occupied by You, 

individually or jointly with another person or entity, or that You have an equitable interest in, 

anywhere in the world, from March 1, 2018, through the date of Your response, including but not 

limited to lease agreements and/or contracts for the real properties located at:

a) 18117 Biscayne Blvd., Apt. 2031, Aventura, FL 33160

b) 375 South Hibiscus Dr., Miami Beach, FL 33139

2. Complete copy of the closing file, including, without limitation, copies of any and all promissory 

notes, mortgages, HUD-1s, listing agreements, closing statements, settlement statements, 

addendums, deeds, mortgage or loan applications, and payment documents, for all real property in 

which You have or had an interest in for the four (4) years up to and including the Petition Date.

3. Copy of any homeowner’s, renter’s insurance policy(ies), or personal articles policy(ies) in the 

four (4) years up to and including the Petition Date.

4. Any and all documents that evidence, refer or relate to any insurance claims made in the four (4)

years up to and including the Petition Date related to any real property including, but not limited 

to those properties listed in Request 1, supra, including dates of claims, amounts of claims, 

amounts paid by insurance, dates of payments, and use of funds. 

5. All documents related to any proceeds You received from the sale, transfer, or other disposition of 

any real property in the four (4) up to and including the Petition Date.

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6. Copy of any lease, rental agreement, purchase agreement, and/or sale agreement or contract with 

respect to any real property that You used, occupied, possessed, owned, rented, or controlled in the 

four (4) years up to and including the Petition Date.

7. Clear, color photographs of each and every room at Your scheduled residence, whether You claim 

an interest in the property or not, both of full room, wide-view and close-ups, interior and exterior, 

including garages, sheds and storage spaces, patios.

B. Personal Property

8. Clear, color photographs of all personal and/or business property, whether You claim an interest 

in the property or not, both full room, wide-view and close-ups of any jewelry, clothing, 

accessories, designer handbags, designer shoes, luggage, electronics (cellular phone, computer, 

tablet), and other valuables, and interiors of closets, cabinets, garages, sheds, storage and patios.

9. Any and all documents that evidence, refer or relate to household goods, furnishings, and fixtures 

that have been purchased by You from March 1, 2018, to present that had a purchase price of $500 

or more.

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

paintings, books, memorabilia, prints, pictures, stamps, cards, art objects) clothing and accessories, 

or jewelry (e.g., watches, rings, heirlooms, gems, gold, silver and precious metals) that You now 

own or have owned from March 1, 2018, to present.

11. All documentation relating any motor vehicles, motorcycles, recreational vehicles, motorhomes, 

trailers, any vessels, watercraft, aircraft, trailers and/or related accessories that you owned, had 

access to and/or control of (whether owned by You or an entity that You are affiliated with, or held 

in trust by You) from March 1, 2018 including, without limitation, appraisals, valuations, 

certificates of title, registrations, proof of insurance, proof of purchase, lienholder and payoff 

information, co-owner information, co-registrant information, lease information, and to the extent 

applicable, proof of sale or transfer including consideration, full name and address of transferee, 

date of transfer, and relationship to You, from March 1, 2018, through present.

C. Personal Financial

12. Provide a complete copy of Your credit report as of the date of production. 

13. Copies of all bank statements (monthly or periodic) and attendant account records (including, but 

not limited to, signature cards, ledger accounts, deposit slips, cancelled checks (front and back), 

check registers, check stubs, debit or credit advices or memos and wire transfers) for all bank 

accounts, both open and closed, personal or business, including virtual bank or merchant accounts, 

in any and all financial institutions, anywhere (foreign or domestic), from March 1, 2018, to 

present, that are in Your name or joint name, or where You are an authorized signer or are an 

interested party of any kind.

14. All payment records, documents, and transaction history for any electronic funds transfers 

including but not limited to Zelle, WhatsApp, Apple Pay, Cash App, Venmo and other money 

transfer applications or web tools.

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15. Any and all documents relating to any cash withdrawals from any of Your bank accounts in the 

last two (2) years up to and including the Petition Date for $500 or more, and a description and 

supporting documents regarding the use of the withdrawn funds.

16. Full accounting of all cash advances taken from any credit card or line of credit within four (4) 

years of the Petition Date, including a description of what the money was used for. 

17. Full accounting of all funds in any retirement account (whether individual or employer sponsored) 

from March 1, 2018, to present, including account statements, withdrawal authorizations, and a 

description of what withdrawn funds were used for. 

18. Full accounting of all funds withdrawn from any insurance policies (whether individual or 

employer sponsored) within four (4) years of the Petition Date, including account statements, 

withdrawal authorizations, and a description of what the funds were used for. 

19. Any and all documents or applications submitted to any bank, financial institution, or any other 

person or entity, by You or for any entity where You are an interested party of any kind, for any 

loan or advance, in any capacity (borrower, guarantor, or surety) from March 1, 2018, to present, 

including but not limited to all credit and/or loan applications, Coronavirus Relief applications, 

and any personal financial statements.

20. All documents that evidence, refer or relate to any interest in, or claimed title to, any financial 

instruments, accounts, or securities, including but not limited to: certificates of deposit, letters of 

credit, money orders, cashier’s checks, traveler’s checks, bank deposits, note receivables, pledges, 

security interests, stocks, bonds, mutual funds, debentures, retirement accounts, annuities, (whether 

individual or employer sponsored), stock options or profit sharing plans, or other investment, either 

owned by You or held for Your benefit.

21. All documents that evidence, refer or relate to any account into which any of Your earnings or 

other income has been deposited from March 1, 2018, to present, whether You continue to have an 

interest in it or not.

22. All documents that evidence, refer or relate to You having authority to access any safe-deposit box 

or other bank-secured area, from March 1, 2018, to present.

23. Copies of all credit card and/or credit line statements (including business accounts) in excess of 

$5,000 listed on Schedule E/F, in addition to any other accounts on which you are an authorized 

signor, including any receipts (if applicable), reflecting all purchases and/or transactions made 

from March 1, 2018, to present.

24. Complete signed copies of all local, state and federal tax returns for the years 2017, 2018, 2019, 

2020 and/or 2021 including all supporting forms, schedules and documentation, such as Forms K1, W-2, 1099 and 1098, and W-4 tax withholding forms, filed by You including any amendments. 

25. All documentation relating to any outstanding government, federal, state, and/or municipal) tax 

obligations, including without limitation, copies of tax liens, that You or any corporation in which 

You are listed as an officer, as of the Petition Date. 

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26. Any and all documents that evidence, refer or relate to a cash value in any life insurance policy 

held by You or for which You are a beneficiary, and copies of all policies, whether term, whole 

life, or universal.

27. Complete copies of all financing statements, factoring agreements, financing agreements, franchise 

agreements, consulting agreements, distribution agreements, employment agreements, partnership 

agreements, licenses, copyright and trademark, intellectual property, website detail, fictitious name 

information, non-proprietary manufacturing agreements, assignments, pledges, and financial 

statements, for You from March 1, 2018, to present, including but not limited to those with:

D. Business Interests 

28. All documents that evidence, refer or relate to Your ownership interest in any business entity in 

the world, including, without limitation, a corporation, limited liability company, partnership, a 

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

professional association and a professional corporation, from March 1, 2018, to present, including, 

but not limited to:

a) The Motorcar Collection, LLC (EIN 27-1749440)

b) Optionguard, LLC

c) Collection Miami, LLC

d) The Motorcar Collection Miami Corp. (EIN 85-0569597)

e) The Motorcar Collection Corp. 

f) Howard Holdings, LLC

g) River Run Unlimited

29. All corporate documents without limitation, any revised or amended versions, from March 1, 2018, 

to present, including but not limited to articles of incorporation, bylaws, shareholder agreements, 

member agreements, meeting minutes, and corporate resolutions, stock certificates, membership 

certificates, and actions by consent of shareholders, members, and/or managers, for any entity in 

which You have or had an ownership, equitable, beneficial or other interest, including any business 

interest identified in request 28, supra. 

30. Provide a USB flash-drive, portable drive, disc, or hard copies of all of the private/direct messages 

sent via Facebook, WhatsApp, Instagram, or any other social media platform, that relates to the 

business dealings/transactions of any of the entities listed in request 28, supra, or any other 

business entity in the world in which You have or had an ownership, equitable, beneficial or other 

interest in from March 1, 2018, to present.

31. Provide a USB flash-drive, portable drive, disc, or hard copies of all of communications in any 

format on or any platform that relate to the business dealings/transactions of any of the entities 

listed in request 28, supra, or any other business entity in the world in which You have or had an 

ownership, equitable, beneficial or other interest in from March 1, 2018, to present.

32. Provide a USB flash-drive, portable drive, or disc containing the accounting data including the 

name of the software used and the passwords required to access the data, from March 1, 2018, to 

present, for any entity in the world in which You have or had an ownership, equitable, beneficial 

or other interest in, including any business interest identified in request 28, supra. 

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33. Signed copies of all local, state and federal tax returns for the years 2017, 2018, 2019, 2020 and/or 

2021 including all supporting forms, schedules and documentation, such as K-1s, W-2s, 1099 and 

1098 forms, W-4 tax withholding forms, and amendments, filed by or for any entity in which You 

have or had an ownership, equitable, beneficial or other interest in, including any business interest 

identified in request 28, supra. 

34. Copies of all corporate financial documents (including, but not limited to, payroll records, signed 

payroll tax returns, profit and loss statements, general ledgers, accounts receivable, inventory, 

accounts payable), from March 1, 2018, to present, for any entity in the world in which You have 

or had an ownership, equitable, beneficial or other interest in since July 1, 2017, including any 

business interest identified in request 28, supra. 

35. Complete copies of all business records, from March 1, 2018 to present, including but not limited 

to, occupational licenses, business licenses (federal, state, county, city), patents, financing 

statements, factoring agreements, financing agreements, franchise agreements, consulting 

agreements, distribution agreements, employment agreements, partnership agreements, licenses, 

copyright and trademark, intellectual property, website detail, fictitious name information, nonproprietary manufacturing agreements, assignments, pledges, and financial statements, for any 

entity in which You have or had an ownership, equitable, beneficial or other interest in from March 

1, 2018 to present, including any business interest identified in request 28, supra. 

36. Copies of any and all statements (periodic or monthly) and all support for all deposits, withdraws 

and transfers (including, without limitation, ledger accounts, memoranda, signatory cards, 

checkbooks, canceled checks (front and back), wire transfers (incoming and outgoing), debit or 

credit advices or memos, deposit slips, withdraw slips and any other records) for all bank accounts 

(open or closed), including all virtual bank or merchant accounts (such as PayPal, Venmo, Cash 

App, Square), in any and all financial institutions, anywhere (foreign and domestic), from March 

1, 2018, to present, where any entity in which You have or had an ownership, equitable, beneficial 

or other interest in since March 1, 2018, to present, was a joint name, authorized signer, exercised 

control, or otherwise had an interest, including any business interest identified in request 28, supra. 

37. All documentation and information regarding any and all transfers of money, property, 

contributions, loans, investments, gifts, cash withdrawals, or payments over $1,000.00, made to 

any person and or any entity outside of the ordinary course of business (including, without 

limitation, any shareholders, principals, officers, directors, owners, employees, contractors or 

agents of the Debtor), from March 1, 2018, to present by any entity in which You have or had an 

ownership, equitable, beneficial or other interest in, including any business interest identified in 

request 28, supra.

38. Copies of any and all financial applications and supporting documents and statements prepared for 

any lender, creditor, or third party, from March 1, 2018, to present, for any entity in which You 

have or had an ownership, equitable, beneficial or other interest in, including any business interest 

identified in request 28, supra. 

39. Copies of any and all Coronavirus Relief documents and applications between any lender, creditor, 

or third party, from March 2020 to the date of production, for any entity in which You have or had 

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an ownership, equitable, beneficial or other interest in, including any business interest identified in 

request 28, supra. 

40. Copies of any and all documents and applications between You, individually or for any entity in 

which You have or had an ownership, equitable, beneficial or other interest in, regarding the 

Personal loan debts listed under Your Schedule E/F. 

41. All documents related to any profit, equity or benefit sharing agreement or joint venture 

arrangement in which any entity in which You have or had an ownership, equitable, beneficial or 

other interest in since March 1, 2018, including any business interest identified in request 28, supra. 

42. All documents, regarding joint business ventures, trusts, arrangements, and/or assets held by You 

or that You participated in with any individuals or entities within four (4) years immediately 

preceding the Petition Date.

E. General / Other

43. Any and all documents that evidence, refer or relate to any gambling or gaming winnings from 

January 1, 2020, to the date of production.

44. Copies of all Your passports, including covers and interior pages, from March 1, 2018, to present.

45. Any and all documents that evidence, refer or relate to any insurance claim or claim of loss made 

by You or any entity You control from March 1, 2018, to the date of production.

46. Any and all documents that evidence, refer or relate to any lawsuit, court action, or administrative 

proceeding, including personal injury cases, small claims actions, collection suits, paternity 

actions, support or custody modifications, evictions, foreclosures, contract disputes, probate, and 

any other proceeding, from March 1, 2018, to the date of production. 

47. All documentation and information regarding any and all transfers of money, contributions, 

investments, property, loans, gifts over $500.00 made by You to any person, party or entity, from 

March 1, 2018, to the date of production.

48. Any and all document that evidence, refer or relate to any storage facility or mini-warehouse, selfstorage 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, including a detailed inventory of stored items, from March 1, 2018, to present.

49. All documentation regarding any and all wills, family trusts, interests in insurance policies, 

equitable or future interests, life estates, and rights or powers exercisable for the benefit of the 

Debtor or where You are named, including any trust in which You are a settlor, trustee, or 

beneficiary and any Will in which You are a beneficiary or personal representative.

50. Complete copies of all professional licenses held by You from March 1, 2018, through present.

* * *

The Trustee reserves the right to request additional documents as the investigation 

continues, as the Examination proceeds, as additional issues are uncovered, and as clarifications 

are required.

Case 22-11866-LMI Doc 56 Filed 06/14/22 Page 12 of 12