Opinion
Civil Action 1:21-CV-014
06-07-2022
BRIDGESTONE AMERICAS TIRE OPERATIONS, LLC d/b/a GCR TIRES AND SERVICE, a Delaware corporation, Plaintiff, v. PRISTINE CLEAN ENERGY, LLC, a West Virginia limited liability company, and WILLIAM K. ABRAHAM, its personal guarantor, Defendants.
RULE 34 REQUEST FOR PRODUCTION OF DOCUMENTS
Pursuant to Rules 30 and 34 of the Federal Rules of Civil Procedure, you are requested to produce the following financial documents for inspection and copying at your deposition to be determined by the Court pursuant to Bridgestone Americas Tire Operations, LLC dba GCR Tires and Service Motion for Deposition in Aid of Execution of Pristine Clean Energy, LLC:
1. All tax returns filed by the Pristine Clean Energy, LLC for the previous four (4) years.
RESPONSE TO REQUEST NO. 1:
2. All documents referred to in any way, directly or indirectly, in any and all tax returns filed by Pristine Clean Energy, LLC for the previous four (4) years.
RESPONSE TO REQUEST NO. 2:
3. All documents that constitute or refer in any way, directly or indirectly, to any and all books, records, or other memoranda of business or financial conduct, activities, status or income of Pristine Clean Energy, LLC for the past four (4) years.
RESPONSE TO REQUEST NO. 3:
4. All documents that constitute or refer in any way, directly or indirectly, to any and all deeds, records, or other documents which relate to assets in the name of Pristine Clean Energy, LLC.
RESPONSE TO REQUEST NO. 4:
5. All documents that constitute or refer in any way, directly or indirectly, to any records of allowances, expenses, or any other sums of money paid to Pristine Clean Energy, LLC or by Pristine Clean Energy, LLC within the previous four (4) years.
RESPONSE TO REQUEST NO. 5:
6. All documents referring in any way, directly or indirectly, to any items of personal property in which Pristine Clean Energy, LLC owns or claims any interest.
RESPONSE TO REQUEST NO. 6:
7. All documents, items, and things referring in any way, directly or indirectly, to any and all accounts (business bank, checking, savings, credit union, or retirement accounts) in which Pristine Clean Energy, LLC has an interest.
RESPONSE TO REQUEST NO. 7:
8. All documents referring in any way, directly or indirectly, to the name and address of persons or entities to whom Pristine Clean Energy, LLC has given a financial statement in the last two (2) years.
RESPONSE TO REQUEST NO. 8:
9. All documents that constitute or refer in any way, directly or indirectly, to financial statements prepared by Pristine Clean Energy, LLC in the last four (4) years.
RESPONSE TO REQUEST NO. 9:
10. All documents containing or referring in any way, directly or indirectly, to the names and addresses of persons who have served as bookkeepers or financial advisers for the Pristine Clean Energy, LLC during the last four (4) years.
RESPONSE TO REQUEST NO. 10:
11. All documents referring in any way, directly or indirectly, to any personal or real property which the Pristine Clean Energy, LLC has sold, given, paid, or otherwise conveyed during the last four (4) years.
RESPONSE TO REQUEST NO. 11:
12. All documents referring in any way, directly or indirectly, to any and all motorized vehicles (including automobiles, trucks, watercraft, aircraft, and motorcycles) in which the Pristine Clean Energy, LLC claims an interest.
RESPONSE TO REQUEST NO. 12:
13. All documents that constitute or refer in any way, directly or indirectly, to any appraisal of any real or personal property prepared for Pristine Clean Energy, LLC during the last two (2) years.
RESPONSE TO REQUEST NO. 13:
14. All documents that evidence or refer in any way, directly or indirectly, to the amount of money owed to the Pristine Clean Energy, LLC by any person or entity.
RESPONSE TO REQUEST NO. 14:
15. All documents referring in any way, directly or indirectly, to any legal cause of action, either real or anticipated, by or against the Pristine Clean Energy, LLC.
RESPONSE TO REQUEST NO. 15:
16. All documents referring in any way, directly or indirectly, to the anticipated amount of recovery in any legal cause of action, either real or anticipated, by Pristine Clean Energy, LLC.
RESPONSE TO REQUEST NO. 16:
17. All documents referring in any way, directly or indirectly, to each person or entity who has served as the bank for Pristine Clean Energy, LLC during the last two (2) years.
RESPONSE TO REQUEST NO. 17:
18. All documents referring in any way, directly or indirectly, to any cash on hand for Pristine Clean Energy, LLC as of the date of the deposition.
RESPONSE TO REQUEST NO. 18:
19. All documents referring in any way, directly or indirectly, to any and all cash in any account owned or claimed by Pristine Clean Energy, LLC held or deposited with any bank or other financial institution(s).
RESPONSE TO REQUEST NO. 19:
20. All documents referring in any way, directly or indirectly, to any accounts payable owed by Pristine Clean Energy, LLC.
RESPONSE TO REQUEST NO. 20:
21. All documents that constitute or refer in any way, directly or indirectly, to any accounts receivable owed to Pristine Clean Energy, LLC.
RESPONSE TO REQUEST NO. 21:
22. All documents that constitute or refer in any way, directly or indirectly, to notes receivable held by Pristine Clean Energy, LLC or in which Pristine Clean Energy, LLC claims an interest.
RESPONSE TO REQUEST NO. 22:
23. All documents referring in any way, directly or indirectly, to shares of stock owned by the Pristine Clean Energy, LLC or in which the Pristine Clean Energy, LLC claims an interest.
RESPONSE TO REQUEST NO. 23:
24. All documents referring in any way, directly or indirectly, to bonds owned by the Pristine Clean Energy, LLC in which the Pristine Clean Energy, LLC claims an interest.
RESPONSE TO REQUEST NO. 24:
25. All documents referring in any way, directly or indirectly, to real estate that the Pristine Clean Energy, LLC owns or in which the Pristine Clean Energy, LLC claims an interest.
RESPONSE TO REQUEST NO. 25:
26. All documents referring in any way, directly or indirectly, to any and all businesses in which Pristine Clean Energy, LLC is a partner, officer, or principal owner.
RESPONSE TO REQUEST NO. 26:
27. All documents referring in any way, directly or indirectly, to any interest the Pristine Clean Energy, LLC may have in any businesses, partnerships, corporations, or joint ventures.
RESPONSE TO REQUEST NO. 27:
28. All documents referring in any way, directly or indirectly, to any equipment that the Pristine Clean Energy, LLC owns or in which the Pristine Clean Energy, LLC claims an interest.
RESPONSE TO REQUEST NO. 28:
29. All documents referring in any way, directly or indirectly, to any other unpaid taxes for which the Pristine Clean Energy, LLC is liable except for those already listed with regard to real estate.
RESPONSE TO REQUEST NO. 29:
30. All documents referring in any way, directly or indirectly, to any assets held in trust, in an estate, or in any other name or capacity in which the Pristine Clean Energy, LLC claims or has an interest.
RESPONSE TO REQUEST NO. 30:
31. All documents referring in any way, directly or indirectly, to assets, except real estate, that are securing any debt for which the Pristine Clean Energy, LLC is liable.
RESPONSE TO REQUEST NO. 31:
32. All documents referring in any way, directly or indirectly, to the Pristine Clean Energy, LLC's obligations to pay the leases, notes, or other debts of any other person or entity.
RESPONSE TO REQUEST NO. 32:
33. All documents referring in any way, directly or indirectly, to any unsatisfied judgments against the Pristine Clean Energy, LLC or for which the Pristine Clean Energy, LLC is liable.
RESPONSE TO REQUEST NO. 33:
34. All documents referring in any way, directly or indirectly, to any filing in bankruptcy by the Pristine Clean Energy, LLC or any assignment by the Pristine Clean Energy, LLC for the benefit of creditors.
RESPONSE TO REQUEST NO. 34:
35. All documents referring in any way, directly or indirectly, to any dividends payable to the Pristine Clean Energy, LLC or in which Pristine Clean Energy, LLC claims an interest.
RESPONSE TO REQUEST NO. 35:
36. All documents referring in any way, directly or indirectly, to any interest payable to the Pristine Clean Energy, LLC or in which the Pristine Clean Energy, LLC claims an interest.
RESPONSE TO REQUEST NO. 36:
37. All documents referring in any way, directly or indirectly, to any royalties payable to the Pristine Clean Energy, LLC or in which the Pristine Clean Energy, LLC claims an interest.
RESPONSE TO REQUEST NO. 37:
38. All documents referring in any way, directly or indirectly, to any insurance payments Pristine Clean Energy, LLC may have or any insurance payments due to Pristine Clean Energy, LLC.
RESPONSE TO REQUEST NO. 38:
39. All documents referring in any way, directly or indirectly, to any other assets not already divulged by Pristine Clean Energy, LLC pursuant to this document request.
RESPONSE TO REQUEST NO. 39:
40. All documents referring in any way, directly or indirectly, to any other liabilities not already divulged pursuant to this document request.
RESPONSE TO REQUEST NO. 40:
41. All documents referring in any way, directly or indirectly, to any outstanding contracts for which Pristine Clean Energy, LLC is entitled to receive a commission, and/or upon which Pristine Clean Energy, LLC claims a right to receive a commission, whether a partial commission or complete commission.
RESPONSE TO REQUEST NO. 41:
42. All documents evidencing safety deposit boxes, lock boxes, and storage facilities of any kind to which Pristine Clean Energy, LLC has access.
RESPONSE TO REQUEST NO. 42:
43. All documents evidencing any trusts and the assets contained therein for trusts of which Pristine Clean Energy, LLC is a grantor, a beneficiary, or trustee.
RESPONSE TO REQUEST NO. 43:
BRIDGESTONE AMERICAS TIRE OPERATIONS, LLC, d/b/a GCR TIRES AND SERVICE
By Counsel
Arnold J. Janicker, Esquire (WV Bar #9071) JENKINS FENSTERMAKER, PLLC