EXHIBIT D 

Case 2:17-cv-04140-DWL Document 182-4 Filed 07/26/19 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT 

FORTHED~TRICTOFARIWNA 

Case No.: 2:17-CV-04140-DWL 

RESPONSE TO SUBPOENA DUCES TECUM 

1. Documents sufficient to show all transfers of funds or payments- whether in cash 

or otherwise, and whether characterized as income, a gift, a loan, or otherwise--

from You to Wyo Tech or Inductance. 

Danzik Applied Sciences, LLC ("DAS") has no documents responsive to this request 

beyond those that have already been produced to CWT and its attorneys as part of 

Elizabeth Danzik's Response on April 10, 2017, to Plaintiffs' First Requests for 

Production in CWT, et al v. Elizabeth Danzik, et al., Arizona District Court Case No. 

2:26-cv-00607, or which were obtained by CWT in response to its subpoena on Wells 

Fargo Bank in late 2017. 

2. Documents sufficient to show all transfers of funds or payments- whether in cash 

or otherwise, and whether characterized as income, a gift, a loan, or otherwise-to 

You or on Your behalf from Wyo Tech or Inductance. 

DAS bas no documents responsive to this request beyond those that have already been 

produced to CWT and its attorneys as part of Elizabeth Danzik's Response on April 

1 O, 2017, to Plaintiffs' First Requests for Production in CWT, et al v. Elizabeth Danzik, 

et al., Arizona District Court Case No. 2:26-cv-00607, or which were obtained by 

CWT in response to its subpoena on Wells Fargo Bank in late 2017. 

3. All documents concerning the transfer of any of Your assets or liabilitiesregardless of whether for consideration- to Wyo Tech or Inductance. 

DAS has no documents responsive to this request beyond those that have already 

been produced to CWT and its attorneys as part of Elizabeth Danzik's Response on 

April 10, 2017, to Plaintiffs' First Requests for Production in CWT, et al v. Elizabeth 

Danzik, et al., Arizona District Court Case No. 2:26-cv-00607, or which were 

obtained by CWT in response to its subpoena on Wells Fargo Bank in late 2017 •• 

4. All documents concerning reimbursement requests made by You to Wyo Tech or 

Inductance. 

DAS has no documents responsive to this request. 

Case 2:17-cv-04140-DWL Document 182-4 Filed 07/26/19 Page 2 of 3
5. All receipts provided by You to Wyo Tech or Inductance. 

DAS has no documents responsive to this request beyond those that have already 

been produced to CWT and its attorneys as part of Elizabeth Danzik's Response on 

April 10, 2017, to Plaintiffs' First Requests for Production in CWT, et al v. Elizabeth 

Danzik, et al., Arizona District Court Case No. 2:26-cv-00607, or which were obtained 

by CWT in response to its subpoena on Wells Fargo Bank in late 2017. 

6. Documents sufficient to show all work that You performed for, or all items you 

bought or services You paid for on behalf of, Wyo Tech or Inductance .. 

DAS has no documents responsive to this request beyond those that have already 

been produced to CWT and its attorneys as part of Elizabeth Danzik's Response on 

April 10, 2017, to Plaintiffs' First Requests for Production in CWT, et al v. Elizabeth 

Danzik, et al., Arizona District Court Case No. 2:26-cv-00607, or which were 

obtained by CWT in response to its subpoena on Wells Fargo Bank in late 2017 .. 

7. All communications between You, on the one hand, and William J. Hinz, on the 

other hand, concerning Wyo Tech or Inductance. 

DAS has no documents responsive to this request. 

8. Your members. 

Elizabeth Danzik, sole member. 

9. Your operation, including the Persons that control You and Your beneficial 

owners. 

DAS ceased operations in the late summer or 2017 and therefore has no documents 

responsive to this request. 

I avow under penalty of perjury that the foregoing responses are true and correct to the 

best of my knowledge. 

Dated: July 10, 2019 

Danzik Applied Sciences, LLC 

Case 2:17-cv-04140-DWL Document 182-4 Filed 07/26/19 Page 3 of 3