The List

This is a list of documents that we demand from the judgment debtor. If there is going to be a settlement after you obtain the judgment, this is where it happens…

This is where the squeaky wheel principal really gets going. Once you have a judgment, you are entitled to demand each and every one of the following documents. In fact, if a defendant will not produce these documents, assuming they exist, the defendant is in contempt of court and can be sent to jail for his contempt. That is where the squeaky wheel really begins and is the step where many of our settlements occur.

This is a sample from the “list,” which is actually more extensive than this:

1. All income tax returns filed by the defendant for the previous four (4) years.
2. All documents referred to in any way, directly or indirectly, in any and all income tax returns filed by defendant for the previous four (4) years.
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 defendant for the past four (4) years.
4. All documents that constitute or refer in any way, directly or indirectly to any and all deed, records, or other documents which relate to assets in the name of defendant.
5. All documents that constitute or refer in any way, directly or indirectly, to any records of salaries, commissions, bonuses, income from employment, allowances, expenses, or any other sums of money paid to defendant or by defendant within the previous four (4) years.
6. All documents that contain or refer in any way, directly or indirectly, to the name(s) and address(es) of the person or persons who have custody of records of salaries, commissions, bonuses, allowances, expenses, or any other sums of money paid to or by defendant within the last four (4) years.
7. All documents referring in any way, directly or indirectly, to any items of personal property in which defendant owns or claims any interest.
8. All documents, items, and things referring in any way, directly or indirectly, to any and all accounts (business or personal bank, checking, savings, credit union, or retirement accounts) in which defendant has an interest.
9. All documents referring in any way, directly or indirectly, to the name and address of persons or entities to whom defendant has given a financial statement in the last two (2) years.
10. All documents that constitute or refer in any way, directly or indirectly, to financial statements prepared in the last four (4) years.
11. All documents referring in any way, directly or indirectly, to the names and addresses of persons who have served as bookkeepers or financial advisers for the defendant during the last four (4) years.
12. All documents referring in any way, directly or indirectly, to each person or entity to whom defendant has paid, given, or conveyed any real or personal property of a value more than $200.00 in the last four (4) years, not in the regular course of business.
13. All documents referring in any way, directly or indirectly, to any personal or real property which the defendant has sold, given, paid, or otherwise conveyed during the last four (4) years.
14. 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 defendant claims an interest.
15. All documents referring in any way, directly or indirectly, to any and all persons or entities who have appraised any real or personal property for the defendant during the last two (2) years.
16. All documents that constitute or refer in any way, directly or indirectly, to any appraisal of any real or personal property prepared for defendant during the last two (2) years.
17. All documents that evidence or refer in any way, directly or indirectly, to the amount of money owed to the defendant by any person or entity.
18. All documents referring in any way, directly or indirectly, to any legal cause of action, either real or anticipated, by or against the defendant.
19. 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 defendant.
20. All documents referring in any way, directly or indirectly, to each person or entity who has served as the bank for Defendant during the last two (2) years.
21. All documents referring in any way, directly or indirectly, to any cash on hand for defendant as of the date of the deposition.
22. All documents referring in any way, directly or indirectly, to any and all cash in account owned or claimed by defendant held or deposited with any bank or other financial institution(s).
23. All documents referring in any way, directly or indirectly, to any accounts receivable owed by Defendant.
24. All documents that constitute or refer in any way, directly or indirectly, to any accounts receivable owed to defendant.
25. All documents that constitute or refer in any way, directly or indirectly, to notes receivable held by defendant or in which defendant claims an interest.
26. All documents referring in any way, directly or indirectly, to shares of stocks owned by the defendant or in which the defendant claims an interest.
27. All documents referring in any way, directly or indirectly, to bonds owned by the defendant or which the defendant claims an interest.
28. All documents referring in any way, directly or indirectly, to real estate that the defendant owns or in which the defendant claims an interest (including homestead).
29. All documents referring in any way, directly or indirectly, to property that the defendant claims as homestead property.
30. All documents referring in any way, directly or indirectly, to any and all business in which defendant is a partner, officer, or principal owner.
31. All documents referring in any way, directly or indirectly, to any interest the defendant may have in any businesses, partnerships, corporations, or joint ventures.
32. All documents referring in any way, directly or indirectly, to any equipment that the defendant owns or in which the defendant claims an interest.
33. All documents referring in any way, directly or indirectly, to mortgage(s) upon which defendant is liable.
34. All documents referring in any way, directly or indirectly, to accounts payable by the defendant, including account name(s), original amount, person or entity to whom due, balance owing, payments, maturity and collateral.
35. All documents referring in any way, directly or indirectly, to accounts payable by the defendant or in which the defendant claims an interest.
36. All documents referring in any way, directly or indirectly, to any other unpaid taxes for which the defendant is liable except for those already listed with regard to real estate.
37. 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 defendant claims or has an interest.
38. All documents referring in any way, directly or indirectly, to any assets that were owned or claimed by the defendant’s spouse before marriage, acquired by the defendant’s spouse during marriage by gift or inheritance, or recovered for personal injuries sustained by the defendant’s spouse during marriage or received in any settlement or judgment pertaining to divorce.
39. All documents referring in any way, directly or indirectly, to assets, except real estate, that are securing any debt for which the defendant is liable.
40. All documents referring in any way, directly or indirectly, to the defendant’s obligations to pay the leases, notes, or other debts of any other person or entity.
41. All documents referring in any way, directly or indirectly, to any unsatisfied judgments against the defendant or for which the defendant is liable.
42. All documents referring in any way, directly or indirectly, to any filing in bankruptcy by the defendant or any assignment by the defendant for the benefit of creditors.
43. All documents referring in any way, directly or indirectly, to any dividends payable to the defendant or in which defendant claims an interest.
44. All documents referring in any way, directly or indirectly, to any interest payable to the defendant or in which the defendant claims an interest.
45. All documents referring in any way, directly or indirectly, to any royalties payable to the defendant or in which the defendant claims an interest.
46. All documents referring in any way, directly or indirectly, to any personal or business expense of defendant (management, rent, household, etc.).
47. All documents referring in any way, directly or indirectly, to any insurance payments defendant may have or any insurance payments due to defendant.
48. All documents referring in any way, directly or indirectly, to any other assets not already divulged by defendant pursuant to this document request.
49. All documents referring in any way, directly or indirectly, to any other liabilities not already divulged pursuant to this document request.
50. All documents referring in any way, directly or indirectly, to any outstanding contracts for which defendant is entitled to receive a commission, and/or upon which defendant claims a right to receive a commission, whether a partial commission or complete commission.
51. Any will executed but not revoked in writing by defendant.
52. All documents referring to any divorce of defendant within the last four (4) years.
53. All check stubs, canceled checks and bank statements for the previous two (2) years for accounts in which defendant claims an interest.
54. All documents evidencing safety deposit boxes, lock boxes, and storage facilities of any kind to which defendant has access.