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-1- COMMONWEALTH OF MASSACHUSETTS BRISTOL, ss PROBATE AND FAMILY COURT NO: Smith, Wendy ) Plaintiff ) ) PLAINTIFF'S FIRST REQUEST vs. ) FOR PRODUCTION OF DOCUMENTS ) Smith, Harry ) Defendant ) -------------------------- Pursuant to Mass. R. Dom. Rel. P. 34(a) and (b), the requests that the documents and other things described below be produced for inspection and copying by the Plaintiff's attorney, Rebecca L. Ferzan, at the Law Offices of Rebecca L. Ferzan, 487 Rock Street, Somerset, Massachusetts 02725. Pursuant to said Rule, you are to serve your written response within thirty (30) days after the service of this request. In lieu of producing the original documents, the Plaintiff’s attorney of record will accept legible photocopies of all documents requested. Said copies are to be served on or before the date called for your response. DEFINITIONS 1. "Document" shall mean any written, graphic or other matter whether produced, reproduced or stored on paper, cards, or other like substance and shall include, without limitation, matter in the form of books, reports, statements, notebooks, application, agreements, appointment calendars, working papers, graphs, manuals, contracts, memoranda, notes, records, correspondence, diaries, bookkeeping entries, and any published materials and shall include, without limitation, originals, copies (with or without notes or changes thereon) and drafts. 2. "Person" shall mean any natural person, corporation, organization, group or body, including both the plural and the singular. 3. "Communications" shall mean and refer to all oral conversations or statements and all writings between two or more persons, including but not limited to, correspondence by letters, notes, telegrams, telex or telecopies and all other electronic means for storing or transmitting information or data.
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-2- If you claim that any requested document is privileged or constitutes attorney work product, you shall submit for each such document, in lieu thereof, a written statement which: 1. Identifies the date of the document; 2. Identifies the author or preparer of the document; 3. Briefly describes the general subject matter or contents of the document; 4. Identifies the person to whom the document was addressed and each person who received a copy of it; 5. Lists the privilege(s) claimed. REQUEST NO. 1 All federal and state income tax returns filed by you individually or jointly with another, together with accompanying worksheets and supporting vouchers, receipts and all other records substantiating said returns, which were filed at any time, from January 1, 2003 to the present time. REQUEST NO. 2 All federal and state tax returns filed by you individually or jointly with another, or on behalf of any business in which you have an interest, together with accompanying worksheets, vouchers, receipts and all other records substantiating said returns, together with profit and loss statements, for any and all partnerships, corporations, trusts, joint ventures, or other corporate or business associations in which you have held or hold any legal or beneficial interest, filed at any time from January 1, 2003 to the present time.
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