Discovery-REQUEST-POD.doc - COMMONWEALTH OF MASSACHUSETTS BRISTOL ss Smith Wendy Plaintiff vs PROBATE AND FAMILY COURT NO PLAINTIFF'S FIRST REQUEST FOR

Discovery-REQUEST-POD.doc - COMMONWEALTH OF MASSACHUSETTS...

This preview shows page 1 - 3 out of 11 pages.

-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.
Image of page 1

Subscribe to view the full document.

-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.
Image of page 2
Image of page 3
  • Fall '18

What students are saying

  • Left Quote Icon

    As a current student on this bumpy collegiate pathway, I stumbled upon Course Hero, where I can find study resources for nearly all my courses, get online help from tutors 24/7, and even share my old projects, papers, and lecture notes with other students.

    Student Picture

    Kiran Temple University Fox School of Business ‘17, Course Hero Intern

  • Left Quote Icon

    I cannot even describe how much Course Hero helped me this summer. It’s truly become something I can always rely on and help me. In the end, I was not only able to survive summer classes, but I was able to thrive thanks to Course Hero.

    Student Picture

    Dana University of Pennsylvania ‘17, Course Hero Intern

  • Left Quote Icon

    The ability to access any university’s resources through Course Hero proved invaluable in my case. I was behind on Tulane coursework and actually used UCLA’s materials to help me move forward and get everything together on time.

    Student Picture

    Jill Tulane University ‘16, Course Hero Intern

Ask Expert Tutors You can ask You can ask ( soon) You can ask (will expire )
Answers in as fast as 15 minutes