Opinion
Case No. 09-CV-12346
08-24-2012
PRESIDENTIAL FACILITY, LLC, a Nevada limited liability company, Plaintiff, v. ROBERT P. PINKAS, an individual, GREGORY S. CAMPBELL, an individual, CHRISTOPHER J. DEBBAS, an individual, and JAMES R. GRIFFITHS, an individual, Defendants.
Hon. Lawrence P. Zatkoff
ORDER COMPELLING CREDITOR'S EXAMINATIONS
AND FOR OTHER POST-JUDGMENT RELIEF
At a session of the Court
held on August 24, 2012
The Court having read plaintiff Presidential Facility, LLC's (Presidential's) motion to compel creditor's examinations and for other post-judgment relief;
IT IS HEREBY ORDERED:
1. Presidential's motion shall be, and is hereby, granted.
2. Each of Jane Pinkas, Gregory S. Campbell and Christopher J. Debbas shall appear to be deposed at creditor's examination at the offices of plaintiff's counsel, 2290 First National Building, 660 Woodward Avenue, Detroit, Michigan 48226 at a date and time of plaintiff's counsel's choosing, with at least fifteen days written notice.
3. Each of the deponents shall bring with him or her to deposition the documents attached as Exhibit 1 hereto.
4. Each of defendants is hereby restrained and enjoined from transferring or disposing of any property owned by him or her, except in ordinary course, until such time as the judgment of May 16, 2012 is paid in full or until further order of the Court, whichever occurs sooner.
Lawrence P. Zatkoff
UNITED STATES DISTRICT COURT JUDGE
EXHIBIT 1
1. All financial statements executed in connection with loan applications, mortgage applications, children's education or otherwise from 2007 to present.
2. Federal, state and local tax returns from 2007 to present.
3. Gift tax returns from 2007 to present.
4. All trust documents in which the debtor has a current or contingent interest as a settlor, beneficiary, trustee, owner or personal representative.
5. All grantor trust documents.
6. All documents evidencing transfers to trustees, nominees, relatives or others for the debtor's benefit.
7. All documents evidencing shareholding or membership or partnership interests in corporations, LLCs or partnerships.
8. All documents reflecting legal or equitable ownership of securities.
9. All brokerage house statements.
10. All documents showing all property held as joint tenants by the entireties or tenants in common (with or without undivided interests).
11. All documents evidencing interests in real estate, as an owner (in fee simple or otherwise), lessee or remainderman.
12. All documents evidencing sums owed by third persons to the judgment debtors, including, but not limited to, promissory notes, purchase and sale agreements and lease agreements.
13. All documents evidencing all sources of income, including, without limitation, salary, dividends, payments, royalties, commissions and assignments of income (including payments pursuant to patent or other licensing arrangements).
14. All documents evidencing the content and location of safety deposit boxes owned by the judgment debtor or to which debtor has a right of access.
15. All documents evidencing conveyance of real or personal property at any time in the past three years.
16. All documents evidencing interests in:
a. antiques;
b. coin or stamp collections;
c. livestock;
d. musical instruments;
e. patents, inventions, trade names, trade secrets, trademarks or copyrights;
f. jewelry;
g. art, artifacts or paintings;
h. fur coats.
17. All insurance policies, including any schedules listing assets.
18. Documents evidencing the deponent's drivers license number and the social security number of deponent and anyone with whom the deponent has any joint ownership as to any asset.
In the case of Jane Pinkas, the documents in question are those pertaining to Robert Pinkas.