NEW YORK STATE SUPREME COURT WESTCHESTER COUNTY DANIEL PETER MORRIS, and Index No. 51874/2017 LUCILLE AIOSA MORRIS, (Formerly Index No. 31136/2010) Plaintiffs, vs. Judge: Compliance Part STEPHANIE L.ZIMMER, Defendant PLAINTIFFS RESPONSE/OBJECTIONS TO DEFENDANT S PAPER ENTITLED DEFENDANT'S ANSWER OF REQUEST FOR PRODUCTION OF DOCUMENTS FROM 8/10/2016 TO PLAINTIFFS DANIEL PETER MORRIS and LUCILLE AIOSA MORRIS DOC. # 29 FILED 05/01/2017 TO THE SUPREME COURT OF THE STATE of NEW YORK ---------------------------------------- DEFENDANT S RESPONSE OF DOCUMENT DEMAND 1 1. A copy of the Complete Auctions operating agreement entered into on creation of Complete Auctions and any subsequent amendments thereto. 4146 DOCUMENT DEMAND 1 DEFENDANT S RESPONSE OF DOCUMENT DEMAND 2 2. For the period 01/01/2003 to 12/31/2007 a copy of all accountings for Complete Auctions prepared by the Defendant in the Defendant's capacity as Managing 1 1 of 6
Member/Member of Complete Auctions, owner or in any other capacity for CompleteAuctions for the entire business activity of Complete Actions in this period. DOCUMENT DEMAND 2 DEFENDANT S RESPONSE OF DOCUMENT DEMAND 3 3. For the period 01/01/2003 to 12/31/2007 a copy of all accountings for CompleteAuctions prepared by anyone of the entire business activity of Complete Actions in this period. DOCUMENT DEMAND 3 DEFENDANT S RESPONSE OF DOCUMENT DEMAND 4 4. For the period 01/01/2003 to 12/31/2007 a copy of all accountings for Complete Auctions prepared by the Defendant in the Defendant's capacity as Managing Member/Member, owner of Auctions or in any other capacity for Complete Auctions for Defendant's business activity in Complete Actions for this period. 2 2 of 6
DOCUMENT DEMAND 4 DEFENDANT S RESPONSE OF DOCUMENT DEMAND 5 5. For the period 01/01/2003 to 12/31/2007 a copy of all evidence Defendant has showing that Complete Auction was a functioning business in this period. 4146 DOCUMENT DEMAND 5 DEFENDANT S RESPONSE OF DOCUMENT DEMAND 6 6. For the period 01/01/2003 to 12/31/2007 a copy of all records of the financial performance of Complete Auctions that Defendant or any sent Plaintiffs. DOCUMENT DEMAND 6 3 3 of 6
DEFENDANT S RESPONSE OF DOCUMENT DEMAND 7 7. For the period O 1/01/2003 to 12/31/2007 a copy of all records of the financial performance of Complete Auctions. DOCUMENT DEMAND 7 DEFENDANT S RESPONSE OF DOCUMENT DEMAND 8 8. For the period 01/01/2004 to 12/31/2007 a copy of the accounting of the business activity of Complete Auctions that Defendant or any Complete Auctions Stakeholder sent Plaintiffs. DOCUMENT DEMAND 8 DEFENDANT S RESPONSE OF DOCUMENT DEMAND 9 9. Copy of signed contract between Complete Auctions and Plaintiffs individually or jointly investing money in Complete Auctions. 4146. 4 4 of 6
DOCUMENT DEMAND 9 DEFENDANT S RESPONSE OF DOCUMENT DEMAND 10 10. For the period 01/01/2003 to 12/3 l/2007a copy of the federal and state income tax returns for Complete Auctions whether filed as an independent entity or included as part of the personal income tax returns of a Complete Auctions. 4146 DOCUMENT DEMAND 10 5 5 of 6
Respectfully submitted, Daniel Peter Morris, Plaintiff, Pro se Attorney Dated: 05/02/2017 Attorney for Plaintiff Lucille Morris P.O. Box 1165 White Plains, NY 10602 Telephone 914-945-3217 6 6 of 6