Comes now Plaintiff, by and through his attorney, D.J. Banovitz, Esq. and hereby submits the following interrogatories on Defendant Maverick Tube Corporation pursuant to C.R.C.P. 69 and 45:
Within 20 days of service of these interrogatories upon the judgment debtor, the judgment debtor shall appear before the clerk of the court in which judgment was entered to sign the answers to the interrogatories under oath and file them.
1. State the name, business address, home address, business phone, home phone, and date of birth of the person answering these questions, and the relationship to the Business:
2. If the Business is a corporation, list the name, home address, business address, home phone, business phone, and date of birth and the title of each officer, direction and shareholder owning 5% or more of the outstanding shares.
3. If the Business is not a corporation, state the form of entity (sole proprietorship, partnership, limited liability company, or otherwise) and list the name, homes address, business address, home phone, business phone, and date of birth and the title of each owner, general or limited partner, or member owning 5% or more of the Business.
4. Provide the EIN and/or Federal Tax Id Number of the Business.
5. List by year, make, model, purchase price, VIN, loan balance, if any, and current location of any and all cars, trucks, motorcycles, boats, trailers, and other motor vehicles owned, used by or titled in the Business during the last four years. If the property is not owned by the Business, list the name and address of the owner. If the property has been transferred to another person or entity, list the name, address and telephone number of the transferee, the date of transfer, and the amount paid by transferee.
6. List each and every financial institution, including banks, savings and loan associations, credit unions, brokerage houses, or otherwise, where the Business is named on an account or has signature authority, including the name, address and telephone number of the institution, the account number, and the current balance of each account.
7. List any and all real or personal property owned by the Business during the last four years, or in which the Business has an interest, where the purchase price or present value exceeds $500.00, including a detailed description, purchase price, current value, amount of any loan balance against the property, and the location including the county. If the property has been transferred to another person or entity, list the name, address and telephone number of the transferee, the date of transfer, and the amount paid by transferee.
8. If the Business owns any property which is leased to another person or entity, identify the property and provide the lessee’s name, address, and phone number, the term of the lease, the amount of lease payments, and the dates that the payments are due.
9. List every person or entity which owes money to the Business in excess of $500.00, including the name, address and phone number, the amount owed, if payments are due, the amount and dates they are due, and the reason the moneys are owed.
10. List every person or entity currently using the services or products of the Business averaging more than $100.00 per month, including the address and phone number, the amount billed or purchased each month, and the billing dates.
11. Produce and attach to your answers, copies of the following documents for the last four years:
- For corporations, the articles of incorporation, bylaws, and corporate minutes.
- For partnerships, the partnership agreement.
- For limited liability companies, the articles of organization and operating agreement.
- For all entities, annual:
- Federal and state tax returns.
- Profit and loss statements.
- Balance sheets.
- Inventory lists.
- Insurance policies, including any excess policies
12 If the Business wishes to propose an arrangement to pay the judgment, state the proposed terms.
If the Business is not longer in business, answer the following questions:
- State the date and exact reasons the Business went out of business.
- If the Business disposed of any of its assets when it went out of business, describe each item which was disposed of, the name, address and telephone number of the person or entity which took possession of the item, any amounts paid for the item, and the reason for the disposition.
- If the Business has any remaining assets, describe each item, including the current value, location and amount of the loan against that item, if any.
- If the Business is in receivership or a trustee has been appointed, provide the name, address and phone number of the receiver or trustee.
- If there are any documents associated with the Business going out of business (e.g., bill of sale, deed in lieu of foreclosure, articles of dissolution), produce and attach them to your answers.
Failure to respond fully, accurately and timely to these interrogatories could result in a citation for contempt of court.
I do hereby affirm under penalty of perjury that I have read each of the above questions and answered them fully and truthfully.
Dated: ________________________________ ___________________________________________
Subscribed and affirmed, or sworn to before me in the County of ______________________, State of ________________, this ___________ day of _______________, 20______.
My Commission Expires: ________________________ ______________________________________ Notary Public /Deputy Clerk
May 1, 2009
Law Office of D.J. Banovitz, L.L.C.
/s/ D.J. Banovitz, Esq.
This pleading was filed electronically pursuant to Rule 121 § 1-26 Original signed pleading is on file in counsel’s office