IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

YOON JA KIM,

Plaintiff,

v.

THE EARTHGRAINS CO.,

k/n/a SARA LEE BAKERY GROUP,

INC.,

Defendant.

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No. 01 cv 3895

Honorable Susan E. Cox

Order Requiring Yoon Ja Kim To Produce Evidence Of Her Assets

To: Yoon Ja Kim, 913 Frances Parkway, Park Ridge, IL, 60068.

YOU ARE COMMANDED to appear in Court on March 11, 2010, at 10:30 a.m. to be

examined under oath to discover assets related to your In Forma Pauperis Application and

Financial Affidavit submitted to this Court on March 18, 2009, under penalty of perjury and with

the understanding that pursuant to 28 U.S.C § 1915(e)(2)(A), the Court shall dismiss this case if

at any time the Court determines that your allegation of poverty is untrue. 

YOU ARE COMMANDED to produce to the Court and defendant’s counsel before the

examination, and by March 5, 2010: copies of the documents set forth on the attached Schedule

A and all books, papers or records in your possession or control which may contain information

concerning your assets, property or income, or indebtedness due. Copies of the set forth

documents shall be delivered to the Court at:

Everett McKinley Dirksen United States Courthouse

219 South Dearborn Street

Chicago, IL 60604 

Chambers Room 1334

and to defendant’s counsel at:

Jenner & Block LLP

c/o Craig C. Martin

353 N. Clark Street

Chicago, IL 60654.

WARNING: YOUR FAILURE TO COMPLY WITH THIS CITATION MAY SUBJECT

YOU TO PUNISHMENT FOR CONTEMPT OF THIS COURT AND/OR TO A

JUDGMENT AGAINST YOU.

Case 1:01-cv-03895 Document 259 Filed 02/26/10 Page 1 of 4
IT IS SO ORDERED.

Dated: February 26, 2010 

 The Honorable Susan E. Cox

 United States District Court

Case 1:01-cv-03895 Document 259 Filed 02/26/10 Page 2 of 4
Schedule A

This Court orders Plaintiff, Yoon Ja Kim, to produce to the Court and to defendant’s counsel of

record, any and all information related to the below topics by March 5, 2010. Unless specified

below, Kim is to produce information related to each topic below for the last ten years. The

information to be produced is not limited to information about assets in the United States, but

includes assets worldwide, and specifically, in Korea. 

The documents Kim is required to produce include, but are not limited to or by, information

regarding the following and any and all documents pertaining to, referring to, relating to,

evidencing and/or supporting the following:

1. Bank statements, checking accounts, savings accounts, money market accounts,

mutual funds, certificates of deposit, safe deposit box signature cards, safe deposit records, trust

accounts, regular accounts, special accounts, security interests, Christmas club accounts, special

savings, thrift accounts, all records of any off shore bank accounts, wire transfers in/out - foreign

and domestic, and signature cards.

2. Kim’s ownership of the forest in Korea she testified about in her January 26, 2010

deposition.

3. Kim’s ownership of the commercial office building in Korea she testified about in

her January 26, 2010 deposition.

4. Kim’s inheritance and her ability to request money from her family in Korea that

she testified about in her January 26, 2010 deposition.

5. Mortgages, deeds of trust, conditional sales contracts, title policies and

homesteads.

6. Any and all pension, retirement or employee savings funds or accounts.

7. Registration certificate(s) and title(s) for all vehicles, aircraft, boats, motorcycles,

trailers, and mobile homes.

8. Stock certificates, stockholder agreements, stock options, bonds, annuities,

commercial paper, and brokerage or commodity accounts. 

9. Cash deposits and cash reserves.

10. Personal property, including: art work, collectables, jewelry, watches, electronic

equipment, guns, furs, coins or bullion, and rugs. 

11. Any and all ownership or other interests, in real estate of any nature whatsoever,

worldwide.

Case 1:01-cv-03895 Document 259 Filed 02/26/10 Page 3 of 4
12. Insurance policies and certificates or schedules of, and for, real and personal

property. 

13. Federal and State income tax returns.

14. Trust Agreements, including information about family trusts.

15. Social Security, disability, life insurance, workers’ compensation, unemployment,

welfare, alimony or maintenance, or child support.

16. Accounts receivable and beneficial interests. 

17. Inheritances, wills and codicils.

18. Payments of, and expectancies to receive, salary, income, wages, consulting fees,

commissions or bonuses or other such fees or compensation from any source whatsoever,

including rent payments, interest, or dividends. 

19. Leases, whether oral or in writing.

20. Any and all ownership interests in any corporation, partnership, firm, business

association, business trust, or other such entity.

21. Any and all interests whatsoever in patents, copyrights, trademarks, service

marks, inventions, or royalty agreements.

22. Custodianship of any and all real property, personal property, tangible property or

intangible property located anywhere worldwide.

23. Any and all real property, personal property, tangible property or intangible

property located anywhere worldwide held by others for your benefit.

24. Indebtedness and liabilities, including notes and/or loan documents.

25. Any and all transfers or conveyances, whether by sale, gift, assignment, pledge,

or other, of any and all real property, personal property, tangible property and intangible

property.

26. Tax returns, and other documents, including documents related to trusts, estates,

and real estate, filed in Korea.

27. Business records, including records of income, related to Research Resources,

Inc. 

28. Records, including any loan and mortgage records, related to the property located

at 913 Frances Parkway, Park Ridge, IL, 60068. 

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