Opinion
2:21-cv-2172-EFM-GEB
10-22-2021
CARPENTERS PENSION TRUST FUND OF KANSAS CITY, et al., Plaintiffs, v. DRYWALL, INC., et al., Defendant.
ORDER SETTING JUDGMENT DEBTOR EXAMINATION
Upon Plaintiff's Motion for Examination of Judgment Debtors, Drywall, Inc. and Robert Knoblauch, and it appearing that this is a proper case for the examination under oath concerning their property, ability, and means to satisfy Plaintiff's May 27, 2021 and July 6, 2021 Orders of Default.
It is hereby ORDERED that Robert Knoblauch appear on Wednesday, November 3, 2021, at 8:30 A.M. before the undersigned in Room 236, United States Courthouse, 500 State Ave., Kansas City, Kansas 66101, to undergo examination under oath concerning Drywall, Inc.'s and Robert Knoblauch's property, ability, and means to satisfy Plaintiff's May 27, 2021 and July 6, 2021 Judgments.
It is further ORDERED that an authorized corporate representative of Defendants Drywall, Inc. and Robert Knoblauch produce copies of the following documents at the examination:
1. All deeds, leases, contracts, and other documentation as to real estate owned by Drywall, Inc. and/or Robert Knoblauch or in which either holds an interest;
2. Evidence of any sale or purchase of real estate made by Drywall, Inc. and/or Robert Knoblauch subsequent to January 22, 2020;
3. All stock certificates, bonds, or other securities in Drywall, Inc. and/or Robert Knoblauch's name or held jointly by Drywall, Inc. and/or Robert Knoblauch and 1 another or others, including options to purchase any securities, along with certification by its broker or banker of the current market value of said stocks, bonds, and securities;
4. All promissory notes, contracts, documents, or papers of any nature, kind, or description whatsoever in which Drywall, Inc. and/or Robert Knoblauch, individually or jointly with another or others, is the present or future payee, obligee, or beneficiary;
5. All contracts or other obligations in effect between Drywall, Inc. and/or Robert Knoblauch and any other individual(s), partnership(s), or corporation(s);
6. Drywall, Inc. and Robert Knoblauch's federal income tax returns for the past three (3) years;
7. Drywall, Inc. and Robert Knoblauch's state income tax returns for the past three (3) years;
8. All of Drywall, Inc. and Robert Knoblauch's bank books and statements from all banks or other financial institutions in which it has an account of any kind, whether as an individual or jointly with another or others, or in the name of a business in which it has or owns an interest;
9. Title and registration certificates for all automobiles and other vehicles in Drywall, Inc. and/or Robert Knoblauch's name, whether individually or jointly with another or others;
10. Proof of all liabilities of Drywall, Inc. and Robert Knoblauch;
11. All credit cards held by Drywall, Inc. and/or Robert Knoblauch;
12. Any other documents, books, records, accounts, or journals tending to show Drywall, Inc. and Robert Knoblauch's net worth;
13. Business records for the present and past calendar years which reflect assets, liabilities, gross receipts, and expenses for any sole proprietorship, partnership, or corporation in which Drywall, Inc. and/or Robert Knoblauch owns any interest;
14. All trust agreements in which, by name or otherwise, Drywall, Inc. and/or Robert Knoblauch is the settlor/trustor/grantor/donor, or the trustee/grantee/donee/beneficiary;
15. All financial statements furnished by Drywall, Inc. and/or Robert Knoblauch to another or others within the past three (3) years; and
16. A schedule of all of Drywall, Inc. and/or Robert Knoblauch's regular or normal monthly disbursements for such items as rent, utilities, repayment of loans, other business expenses, etc., including the amount paid, the name and address of the payee, whether paid by cash, check or money order, and, if payment is on an installment debt, the amount of debt still owing and, if applicable, a description of any property given as security for the debt. 2
It is further ORDERED that a copy of this Order shall be served by the United States Marshal on Drywall, Inc. c/o United States Corporation Agents, Registered Agent, 2000 E. 13th, Hays, KS 67601, AND Robert Knoblauch, 2419 Eastridge Court, Goddard, KS 67052, or where they may be found, as soon as practicable.
It is further ORDERED that the failure of Robert Knoblauch to appear on behalf himself and Drywall, Inc., as ordered, may subject him to arrest and punishment for contempt of this Court. 3