Salameh et al v. Tarsadia Hotel et al

Filing 529

ORDER for Appearance at Examination and For Production of Documents Requested in Exhibit A. Judgment Debtor Exam set for 7/27/2016 10:00 AM before Magistrate Judge Jan M. Adler. Signed by Magistrate Judge Jan M. Adler on 5/23/16.(All non-registered users served via U.S. Mail Service)(dlg)

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UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF CALIFORNIA
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TAMER SALAMEH, et al.,
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Plaintiffs,
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vs.
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TARSADIA HOTELS, et al.
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Defendants.
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_____________________________________ )

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Case No. 09cv2739-GPC (BLM)
(Related to Case No. 11-cv-1842GPC (KSC))
-CL-CL-CJC
ORDER FOR APPEARANCE AT
EXAMINATION AND FOR
PRODUCTION OF DOCUMENTS
REQUESTED IN EXHIBIT A
Date: July 27, 2016
Time: 10:00 AM
Place: Courtroom 1G

IT IS HEREBY ORDERED AS FOLLOWS:
DOLORES GREEN IS ORDERED TO APPEAR PERSONALLY ON JULY 27,

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2016 AT 10:00 AM FOR HER JUDGMENT DEBTOR EXAMINATION BEFORE THE

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ABOVE-CAPTIONED COURT LOCATED AT 221 WEST BROADWAY, SAN DIEGO CA

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92101, COURTROOM 1G, TO FURNISH INFORMATION TO AID IN ENFORCEMENT OF

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A MONEY JUDGMENT AGAINST HER. DOLORES GREEN IS FURTHER ORDERED TO

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PRODUCE THOSE DOCUMENTS LISTED IN EXHIBIT A, ATTACHED HERETO, AND

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INCORPORATED HEREIN BY REFERENCE. JUDGMENT CREDITORS ARE

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ORDER FOR APPEARANCE AT EXAMINATION AND FOR PRODUCTION OF
DOCUMENTS REQUESTED IN EXHIBIT A

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REQUIRED TO SERVE A COPY OF THIS ORDER ON DOLORES GREEN AND FILE A

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PROOF OF SERVICE WITH THE COURT BY JULY 17, 2016.

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NOTICE TO JUDGMENT DEBTOR DOLORES GREEN: If you fail to appear

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at the time and place specified in this order, you may be subject to arrest and

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punishment for contempt of court and the court may make an order

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requiring you to pay the reasonable attorney's fees incurred by the judgment

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creditor in this proceeding.

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IT IS SO ORDERED:

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DATED:

May 23, 2016

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Jan M. Adler
U.S. Magistrate Judge

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ORDER FOR APPEARANCE AT EXAMINATION AND FOR PRODUCTION OF
DOCUMENTS REQUESTED IN EXHIBIT A

EXHIBIT "A"
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Any and all original documents and copies of documents evidencing the existence of any assets
to which Dolores Green (hereinafter referred to as “You” or “Your”) claims a legal or beneficial
ownership and/or interest in, including, but not limited to, the following:
1. All account statements or savings account passbooks showing any deposits
or withdrawals of any funds in any bank, savings and loan institution or brokerage firm within
the last four years;
2.
All retirement account statements showing any balances, deposits,
distributions and loans within the last four years.
3.
All credit card account statements showing any balances, charges or
payments within the last four years.
4. All financial statements prepared by You or on Your behalf within the last
four years;
5. The registrations and certificates of ownership for any automobiles or any
other motor-powered vehicles or boats which You own and/or use, or which are registered in
Your name or names;
6. All notes and/or other documents which evidence any debts owed to You
by any third party;
7. All deeds to real property in which You now claim or have claimed within the last five
years a legal or beneficial interest, or are named as Grantee thereto;
8. All deeds of trust, trust documents or arrangements, life insurance policies,
and annuity policies to which You claim a legal or beneficial interest, or in which you are
named a beneficiary or owner.
9. All stock certificates evidencing ownership in any corporation of which
You claim a legal or beneficial ownership, or in which You are named owner thereto;
10. All documents which evidence Your legal or beneficial interest in any
general or limited partnership, limited liability company, sole proprietorship, or profit or nonprofit corporation.
11. All business accounting books, records, and/or journals including but not
limited to check books, cash disbursements journal and accounts receivable journal;

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12. Any documents which evidence ownership or a legal or beneficial interest
in options to purchase capital stock, commodities, real estate, or commercial deposits, or any
item of value.
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All statements of account evidencing Your current liabilities.

14. Copies of any complaints filed in any court which are now pending in which You are a
party.
15.

Copies of any Judgment now entered against You.

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Copies of any Judgment entered in Your favor.

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Appraisal reports and valuation of all personal property You own, valued at more than
$200.00.
18.
All documents reflecting Your interest in any trusts created by You or for
which You act as trustee or are a beneficiary;
19.
All loans reflecting any money You have borrowed from any one within the last five
years, and all documents reflecting any such loans, including but not limited to applications
filed for such loans, credit reports, notes reflecting such loans, and copies of checks used to pay
said loans.
20.
All loans reflecting any money You have loaned to any third party within the last five
years, and all documents reflecting any such loans, including the name and contact information
of any borrower to whom You have loaned money and copies of payments You have received
for any such loan.
21.
Any employment contracts to which You are a party or have been a party for the last five
years;

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22.

All credit card receipts and invoices for the past four (4) years.

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23.
All documents related to the transfer of real property, to or from You or any entity in
which You claim some interest, within the last 48 months.

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24.
All documents related to the transfer of personal property, to or from You or any entity
in which You claim some interest, within the last 48 months.
25.
Copies of all trust agreements for any irrevocable trust established by You as trustor
(hereafter “Irrevocable Trusts”) including but not limited to those created within the last ten
(10) years;
26.
Copies of all trust agreements for any revocable trusts established by You as trustor
(hereafter “Revocable Trusts”) including but not limited to those created within the last ten (10 )
years;
27.
Copies of all documents evidencing the transfer of any real or personal property to the
Irrevocable Trusts within the last ten (10) years.
28.
Copies of all documents evidencing the transfer of any real or personal property to the
Revocable Trusts within the last ten (10) years.

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29.
All Your corporate records for any corporate entity in which You have an
interest, including but not limited to the following:
a.
b.
c.
d.
e.
f.
g.
h.

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i.
j.

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Articles of Incorporation
By-Laws
Minute Book and all Minutes and Corporate Resolutions of the Corporation
Shareholders Record Book
Shareholders List
All financial records for the last three (3) years
All employment-employee records for the last three (3) years
All employment agreements concerning the corporation and any employee
employed by the corporation during the last three (3) years
Any corporate dissolution agreements
Copy of Your "Notice of Issuance of Securities" and "Consent to Sell Stock"

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30.

All final account statements from all accounts You closed in the last four years.

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Name and contact information of Your accountant.

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Copies of last two pay stubs wherever You are employed or were formerly
employed.

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Your cell phone bills for the last 3 months.

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34.

Your cell phone.

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35.
All communications between You and any other party to the above-referenced
action after the Court issued its fee awards against You on July 31, 2014 for $403,371.25 and on
September 1, 2015 for $130,109.63.

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36.
All documents relating to any property co-owned between You and Zondra
Schmidt and between You and any other third party.

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