Document Demands to Judgment Debtor

___________________________________________________________________________JUDGMENT CREDITOR/PLAINTIFF’S DEMANDS FOR PRODUCTION PROPOUNDED TO JUDGMENT

DEBTOR/ DEFENDANT – SET NO. 1____________/pldg/Post-Jdgmt DFP-1-012813

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SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELES - WEST DISTRICT

_______________,

Plaintiff,

v.

______________, et al.,

Defendants.

)))))))))))

CASE NO. ________________

JUDGMENT CREDITOR’S POST JUDGMENTDEMANDS FOR PRODUCTION PROPOUNDEDTO JUDGMENT DEBTOR/DEFENDANT - SETNO. 1

PROPOUNDING PARTY: JUDGMENT CREDITOR/PLAINTIFF ________________

RESPONDING PARTY: JUDGMENT DEBTOR/DEFENDANT ________________

SET NO.: ONE

Judgment Creditor/Plaintiff Richard Ziman hereby demands, pursuant to Code of Civil

Procedure § 2031.010, et seq., that Judgment Debtor/Defendant ________ (“Debtor”) produce

and permit the inspection and copying of the following writings, documents and things

described below, at the offices of David L. Gernsbacher, 9107 Wilshire Boulevard, Suite 450,

Beverly Hills, California 90210, within 30 days after service of these Post-Judgment Demands for

Production - Set No. 1.

In responding to these Demands for Production, Debtor is obligated to furnish all

information which is available to Debtor, including that which has been obtained by, and

which is now in the possession, custody and/or control of, Debtor’s counsel, employees,

DAVID L. GERNSBACHER SBN895969107 Wilshire Blvd Ste 450Beverly Hills CA 90210-5535Tel: 310-550-0125Fax: 310-550-0608Email: [email protected] for Judgment Creditor/Plaintiff ____________



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agents, insurers, independent contractors, representatives, successors, assigns or others,

and not merely information known by Debtor or of Debtor’s own knowledge.

DEFINITIONS

1. “WRITINGS” means:

a. All written, typed, or other graphic materials of any kind or nature, and any other

tangible thing by which information or data is stored, including, without limitation, any writings

as defined by Evidence Code section 250, including any originals as defined by Evidence

Code section 255, and any duplicates as defined by Evidence Code section 260, any drawing,

film, graph, chart, photograph, phone record, mechanical or electrical sound recording, or

transcript thereof, any retrievable data, whether in computer storage, carded, punched, taped,

coded or stored electronically, electrostatically, electromagnetically, or otherwise, and any

other data compilation from which information can be obtained (including, without limitation, all

emails and attachments thereto).

b. All agreements, draft agreements, calendars, calendar appointment logs, telephone

messages, telephone logs, forms, facsimile transmissions, cancelled checks, bank

statements, financial statements, loan applications, leases, diaries, worksheets, abstracts,

summaries, notes, jottings, audits, charts, diagrams, newspapers, expense reports,

appraisals, rent rolls, income tax returns, title reports, inspection reports, tax notices,

privileged communication logs, papers, books, communications, emails, letters, reports,

proposals, letters of intent, commitment letters, loan applications, correspondence,

memoranda, telegrams, cables, notations, work papers, draft documents, statements,

opinions, studies, affidavits, declarations, analyses, evaluations, transcripts, minutes,

recordings, tapes, photographs, slides, films, and any other sound or visual recordings on any

media, contracts, instructions, charts, manuals, brochures, publications, schedules, computer

printouts, microfilm, books of account, journals, ledgers, records, and all things similar to any

of the foregoing however denominated, including all partial and complete copies, drafts and

final versions thereof, and attachments and enclosures therewith.

c. All materials as described above within the possession, custody or control of



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Judgment Debtor/Defendant ________ (“Debtor”) or any of his duly authorized

representatives, including employees, attorneys, accountants, consultants, advisors, agents

or other representatives. Without limiting the term “control,” a document is deemed to be

within the control of Debtor if Debtor has ownership, possession or custody of the document,

or the right to secure the document from any person or public or private entity having physical

possession thereof.

2. “DEBTOR” means Judgment Debtor/Defendant ________________ or any of his duly

authorized representatives, including employees, attorneys, accountants, consultants,

advisors, agents or other representatives.

3. “CONCERNING” means referring to, relating to, concerning, involving, in connection

with, relevant to, comprising, mentioning, evidencing, supporting and establishing.

WRITINGS TO BE PRODUCED

1. All DEBTOR’s personal and business checking account checks from March 2010 to

the present.

2. All DEBTOR’s personal and business checking account deposit slips from March

2010 to the present.

3. All DEBTOR’s personal and business checking account statements from March 2010

to the present.

4. All DEBTOR’s personal and business savings account checks from March 2010 to

the present.

5. All DEBTOR’s personal and business savings account deposit slips from March 2010

to the present.

6. All DEBTOR’s personal and business savings account statements from March 2010

to the present.

7. All DEBTOR’s personal and business money market account checks from March


8. All DEBTOR’s personal and business money market account deposit slips from

March 2010 to the present.



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9. All DEBTOR’s personal and business money market account statements from March


10. All other of DEBTOR’s financial institution account checks from March 2010 to the

present.

11. All DEBTOR’s financial institution deposit slips from March 2010 to the present.

12. All DEBTOR’s financial institution account statements from March 2010 to the

present.

13. All DEBTOR’s spouse’s personal and business checking account checks from March


14. All DEBTOR’s spouse’s personal and business checking account deposit slips from


15. All DEBTOR’s spouse’s personal and business checking account statements from


16. All DEBTOR’s spouse’s personal and business savings account checks from March


17. All DEBTOR’s spouse’s personal and business savings account deposit slips from


18. All DEBTOR’s spouse’s personal and business savings account statements from


19. All DEBTOR’s spouse’s personal and business money market account checks from


20. All DEBTOR’s spouse’s personal and business money market account deposit slips

from March 2010 to the present.

21. All DEBTOR’s spouse’s personal and business money market account statements

from March 2010 to the present.

22. All other of DEBTOR’s spouse’s financial institution account checks from March 2010

to the present.



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23. All DEBTOR’s spouse’s financial institution deposit slips from March 2010 to the

present.

24. All DEBTOR’s spouse’s financial institution account statements from March 2010 to

the present.

25. All DOCUMENTS including, but not limited to, monthly, quarterly, or other periodic

statements, cancelled checks, deposit slips, wire transfers, etc. CONCERNING any domestic

or foreign bank or other financial account, regardless of how such account is titled, over which

DEBTOR had signatory authority or other such control at any time during the period from


26. Copies of all correspondence, notes, memoranda, written by DEBTOR or received by

DEBTOR regarding any account(s) identified in response to Document Request No. 25,

above.

27. All DOCUMENTS including, but not limited to, all credit, debit and/or ATM card

statements of account, wherever located and regardless of whose name appears on the

account(s), from March 2010 to the present, for such card(s) which DEBTOR uses and/or

used or which DEBTOR has and/or had signatory authority or other such control.


DEBTOR CONCERNING any account(s) identified in response to Document Request No. 27,

above.

29. All DOCUMENTS including, but not limited to, all receipts, statements, deposit slips,

wire transfer memoranda, debit slips, electronic mail messages, and other such documents

CONCERNING any funds, stock and/or property having a value in excess of $500.00

transferred by DEBTOR (individually or in any capacity) from March 2010 to the present.


DEBTOR regarding any transfers identified in response to Document Request No. 29, above.

31. All DOCUMENTS including, but not limited to, monthly, quarterly, or other periodic

statements, cancelled checks, deposit slips, wire transfers, etc. CONCERNING any domestic



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or foreign bank or other financial account, regardless of how such account is titled, over which

DEBTOR had signatory authority or other such control at any time during the period from



DEBTOR regarding any account(s) identified in response to Document Request No. 31,

above.

33. All DOCUMENTS including, but not limited to, all credit, debit and/or ATM card

statements of account, wherever located and regardless of whose name appears on the

account(s), from March 2010 to the present, for such card(s) which DEBTOR’s spouse uses

and/or used or which DEBTOR’s spouse has and/or had signatory authority or other such

control.

34. Copies of all correspondence, notes, memoranda, written by DEBTOR’s spouse or

received by DEBTOR’s spouse CONCERNING any account(s) identified in response to

Document Request No. 33, above.




transferred by DEBTOR’s spouse (individually or in any capacity) from March 2010 to the

present.


received by DEBTOR’s spouse regarding any transfers identified in response to Document

Request No. 35, above.




transferred by DEBTOR’s spouse’s spouse (individually or in any capacity) from March 2010

to the present.



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received by DEBTOR’s spouse CONCERNING any transfers identified in response to

Document Request No. 37, above.

39. Copies of all documents, including but not limited to, correspondence, wire transfers,

memoranda, notes, statements from brokerage, bank or other financial accounts, etc.,

CONCERNING the purchase, transfer and sale of precious metals, including gold, from March

2010 to the present by DEBTOR and/or for DEBTOR’s benefit.

40. Copies of all documents, including but not limited to, correspondence, wire transfers,

memoranda, notes, statements from brokerage, bank or other financial accounts, etc.,

CONCERNING the purchase, transfer and sale of precious metals, including gold, from March

2010 to the present by DEBTOR’s spouse and/or for DEBTOR’s spouse’s benefit.

41. All DOCUMENTS CONCERNING any and all retirement accounts held by and/or on

behalf of Kaplan.

42. All DOCUMENTS CONCERNING any and all retirement accounts held by and/or on

behalf of Kaplan’s spouse.

43. All DOCUMENTS CONCERNING the ownership of DEBTOR’s law practice.

44. All DOCUMENTS CONCERNING the business entity structure of DEBTOR’s law

practice.

45. All DOCUMENTS CONCERNING income derived by DEBTOR’s law practice for the

period March 2010 to the present.

46. All DOCUMENTS CONCERNING income derived by DEBTOR for the period March


47. All DOCUMENTS CONCERNING any real property in which DEBTOR holds any

interest, legal and/or equitable, directly or indirectly.

48. All DOCUMENTS CONCERNING any real property in which DEBTOR’s spouse

holds any interest, legal and/or equitable, directly or indirectly.

49. All DOCUMENTS CONCERNING all liability insurance policies in which DEBTOR is

a named insured in effect for the period March 2010 to the present.



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50. All DOCUMENTS CONCERNING all fire and casualty insurance policies in which

DEBTOR is a named insured in effect for the period March 2010 to the present.

51. All DOCUMENTS CONCERNING all umbrella insurance policies in which DEBTOR

is a named insured in effect for the period March 2010 to the present.

52. All DOCUMENTS CONCERNING all automobile insurance policies in which

DEBTOR is a named insured in effect for the period March 2010 to the present.

53. All DOCUMENTS CONCERNING all disability policies in which DEBTOR is a named

insured in effect for the period March 2010 to the present.

54. All DOCUMENTS CONCERNING all life insurance policies in which DEBTOR is a

named insured in effect for the period March 2010 to the present.

55. All DOCUMENTS CONCERNING all policies of life insurance insuring DEBTOR’s

life in existence during the period March 2010 to the present.

56. All DOCUMENTS CONCERNING all policies of life insurance for which DEBTOR is

a beneficiary in existence during the period March 2010 to the present.

57. All DOCUMENTS CONCERNING other insurance policies and declarations,

including life, automobile, umbrella, homeowner’s, disability, life, fire and casualty, maintained

by DEBTOR and/or on DEBTOR ‘s behalf, regardless of whether DEBTOR is/was the insured,

owner or beneficiary of the policy, in effect since March 2010 to the present.

58. All DOCUMENTS CONCERNING all liability insurance policies in which DEBTOR’s

spouse is a named insured in effect for the period March 2010 to the present.

59. All DOCUMENTS CONCERNING all fire and casualty insurance policies in which

DEBTOR’s spouse is a named insured in effect for the period March 2010 to the present.

60. All DOCUMENTS CONCERNING all umbrella insurance policies in which DEBTOR’s


61. All DOCUMENTS CONCERNING all automobile insurance policies in which

DEBTOR’s spouse is a named insured in effect for the period March 2010 to the present.

62. All DOCUMENTS CONCERNING all disability policies in which DEBTOR’s spouse is

a named insured in effect for the period March 2010 to the present.



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63. All DOCUMENTS CONCERNING all life insurance policies in which DEBTOR’s


64. All DOCUMENTS CONCERNING all policies of life insurance insuring DEBTOR’s

spouse’s life in existence during the period March 2010 to the present.

65. All DOCUMENTS CONCERNING all policies of life insurance for which DEBTOR’s

spouse is a beneficiary in existence during the period March 2010 to the present.

66. All DOCUMENTS CONCERNING other insurance policies and declarations,

including life, automobile, umbrella, homeowner’s, disability, life, fire and casualty, maintained

by DEBTOR’s spouse and/or on DEBTOR ‘s spouse’s behalf, regardless of whether

DEBTOR’s spouse is/was the insured, owner or beneficiary of the policy, in effect since March


67. All title records of all automobiles DEBTOR has driven for more than 48 hours during

the period March 2010 to the present.

68. All of DEBTOR’s credit card statements from March 2010 to the present.

69. All stubs for paychecks DEBTOR has received for the period March 2010 to the present.

70. All DOCUMENTS CONCERNING all expenditures of money by DEBTOR in excess

of $500 for the period March 2010 to the present.

71. All title records of all automobiles DEBTOR’s spouse has driven for more than 48

hours during the period March 2010 to the present.

72. All of DEBTOR’s spouse’s credit card statements from March 2010 to the present.

73. All stubs for paychecks DEBTOR’s spouse has received for the period March 2010 to

the present.

74. All DOCUMENTS CONCERNING all expenditures of money by DEBTOR’s spouse in

excess of $500 for the period March 2010 to the present.

75. All DOCUMENTS CONCERNING DEBTOR’s employment for the period March 2010

to the present.

76. All DOCUMENTS CONCERNING DEBTOR’s acquisition of stocks and bonds for the




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77. All DOCUMENTS CONCERNING DEBTOR’s ownership of stocks and bonds for the


78. All DOCUMENTS CONCERNING DEBTOR’s disposition of stocks and bonds for the


79. All DOCUMENTS CONCERNING DEBTOR’s souse’s employment for the period


80. All DOCUMENTS CONCERNING DEBTOR’s spouse’s acquisition of stocks and

bonds for the period March 2010 to the present.

81. All DOCUMENTS CONCERNING DEBTOR’s spouse’s ownership of stocks and


82. All DOCUMENTS CONCERNING DEBTOR’s spouse’s disposition of stocks and


83. All DOCUMENTS CONCERNING any and all investments held by or on behalf of

DEBTOR during the period March 2010 to the present.

84. All DOCUMENTS CONCERNING any and all businesses in which DEBTOR held an

interest, legal or equitable, during the period March 2010 to the present.

85. All DOCUMENTS CONCERNING all annuities for which DEBTOR is a beneficiary in

existence during the period March 2010 to the present.

86. All DOCUMENTS CONCERNING all loans owed to DEBTOR or to others for the

benefit of DEBTOR.

87. All DOCUMENTS CONCERNING all loans owed by DEBTOR.

88. All DOCUMENTS CONCERNING all indebtedness owed by DEBTOR.

89. All mortgage statements for loans secured by real property in which DEBTOR holds

any interest, legal or equitable.

90. All DOCUMENTS CONCERNING any and all investments held by or on behalf of

DEBTOR’s spouse during the period March 2010 to the present.

91. All DOCUMENTS CONCERNING any and all businesses in which DEBTOR’s

spouse held an interest, legal or equitable, during the period March 2010 to the present.



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92. All DOCUMENTS CONCERNING all annuities for which DEBTOR’s spouse is a

beneficiary in existence during the period March 2010 to the present.

93. All DOCUMENTS CONCERNING all loans owed to DEBTOR’s spouse or to others

for the benefit of DEBTOR’s spouse.

94. All DOCUMENTS CONCERNING all loans owed by DEBTOR’s spouse.

95. All DOCUMENTS CONCERNING all indebtedness owed by DEBTOR’s spouse.

96. All mortgage statements for loans secured by real property in which DEBTOR’s

spouse holds any interest, legal or equitable.

97. DEBTOR’s current passport.

98. DEBTOR’s current driver’s license.

99. DEBTOR’s Social Security card.

100. DEBTOR’s spouse’s current passport.

101. DEBTOR’s spouse’s current driver’s license.

102. DEBTOR’s spouse’s Social Security card.

103. DEBTOR’s current state bar card(s).

104. All DEBTOR’s personal and business income and expense statements for the period


105. All DEBTOR’s personal and business profit and loss statements for the period March


106. All DEBTOR’s personal and business quarterly statements for 2011.

107. All DEBTOR’s personal and business quarterly statements for 2012.

108. All DEBTOR’s personal and business year-end statements for 2011.

109. All DEBTOR’s personal and business year-end statements for 2012.

110. All applications for credit made by and/or behalf of DEBTOR during the period March


111. All DEBTOR’s spouse’s personal and business income and expense statements for

the period March 2010 to the present.



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112. All DEBTOR’s spouse’s personal and business profit and loss statements for the


113. All DEBTOR’s spouse’s personal and business quarterly statements for 2011.

114. All DEBTOR’s spouse’s personal and business quarterly statements for 2012.

115. All DEBTOR’s spouse’s personal and business year-end statements for 2011.

116. All DEBTOR’s spouse’s personal and business year-end statements for 2012.

117. All applications for credit made by and/or behalf of DEBTOR during the period March


118. All DOCUMENTS CONCERNING all assets with a value of more than $500 held by

and/or on behalf of DEBTOR during the period March 2010 to the present.

119. All DOCUMENTS CONCERNING all assets with a value of more than $500 held by

and/or on behalf of DEBTOR’s spouse during the period March 2010 to the present.

120. All DOCUMENTS CONCERNING all liabilities of more than $500 owed by and/or on

behalf of DEBTOR during the period March 2010 to the present.

121. All DOCUMENTS CONCERNING all liabilities of more than $500 owed by and/or on

behalf of DEBTOR’s spouse during the period March 2010 to the present.

122. All DOCUMENTS CONCERNING any domestic and/or foreign trust in which

DEBTOR is a settlor, trustee, trust protector and/or beneficiary.


DEBTOR was (but is no longer) a settlor, trustee, trust protector and/or beneficiary.

124. All DOCUMENTS signed by DEBTOR establishing, modifying, amending or

pertaining to any domestic and/or foreign trust in which DEBTOR is a settlor, trustee, trust

protector, and/or beneficiary since March 2010 to the present.


DEBTOR’s spouse is a settlor, trustee, trust protector and/or beneficiary.


DEBTOR’s spouse was (but is no longer) a settlor, trustee, trust protector and/or beneficiary.



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127. All DOCUMENTS signed by DEBTOR’s spouse establishing, modifying, amending or

pertaining to any domestic and/or foreign trust in which DEBTOR’s spouse is a settlor, trustee,

trust protector, and/or beneficiary since March 2010 to the present.

128. All DOCUMENTS reflecting that any interest(s) DEBTOR may have in a family

limited partnership.

129. All DOCUMENTS CONCERNING the disposition, transfer, purchase, or sale of any

or all or any interest in an asset owned by and/or held on behalf of DEBTOR from March 2010

to the present.

130. All DOCUMENTS CONCERNING the disposition, transfer, purchase, or sale of any

or all or any interest in an asset owned by and/or held on behalf of DEBTOR’s spouse from


131. All DOCUMENTS CONCERNING any lawsuits in which DEBTOR is a party since


132. All DOCUMENTS CONCERNING any lawsuits in which DEBTOR’s spouse is a party

since March 2010 to the present.

Dated: January 28, 2013

______________________________David L. GernsbacherAttorney for Plaintiff Ronnie Gamaty



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PROOF OF SERVICE – MAIL

I am over the age of 18 and not a party to the within action. My business address is 9107Wilshire Boulevard, Suite 450, Beverly Hills, CA 90210.

On ___________, 2013, a true and correct copy of the foregoing Judgment Creditor’sPost-Judgment Demands for Production Propounded to Judgment Debtor/Defendant -Set No. 1 was placed in a stamped envelope and deposited with the U.S. Postal Service atBeverly Hills, California, addressed to the intended recipient set forth below

_________________________________

I declare under penalty of perjury under the laws of the State of California that theforegoing is true and correct.

Executed on ___________, 2013, at Los Angeles County, California.

___________________________

Document Demands to Judgment Debtor

Documents

Transcript of Document Demands to Judgment Debtor