[date] The Honorable RE: John Doe v. John Foe, Case No.: Dear Judge : Enclosed herewith please find the following: 1. Original Ex-Parte Motion for Break Order. 2. Original Affidavit in Support of Plaintiff s Motion for Break Order. 3. Original and one copy of a proposed Order Granting Plaintiff s Ex-Parte Motion for Break Order. 4. Original Notice of Posting $500.00 Cash Bond and our firms check in the amount of $500.00. As a matter of background, on or about, Plaintiff submitted Instructions for Levy to the County Sheriff s Office in connection with levying upon a certain, VIN# owned by the Defendant, John Foe, located at [address]. The levy was to be implemented pursuant to the Final Judgment entered against the Defendant by the Court on. The Judgment is outstanding and has not been paid. The Sheriff s office advised counsel for Plaintiff that the vehicle may be located in a building or structure at the Defendant s residence. As a result, Plaintiff is submitting this Ex-Parte Motion and Break Order to the Court for entry so that Plaintiff is able to carry out the subject levy and Defendant is not able to avoid same because of the easy movability of the subject vehicle. Plaintiff has offered to post a cash bond in the amount of $500.00 to protect against any damages that may be experienced by Defendant in connection with the execution of the subject Break Order. If the Court concurs with Plaintiff s Motion, would Your Honor kindly enter the enclosed Order granting same. Sufficient copies of the proposed Order and self-addressed, stamped envelopes have been provided for the convenience of the Court in forwarding the Order as entered to the respective parties. Thank you for your time and courtesies. Very truly yours, Harvey Dent, Esq.
IN THE CIRCUIT COURT OF THE 15 TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CIVIL DIVISION CASE NO.: JOHN DOE, v. JOHN FOE, Plaintiffs, Defendant. / EX-PARTE MOTION FOR BREAK ORDER COMES NOW, the Plaintiff, JOHN DOE, and hereby moves the Court on an Ex-Parte basis and as grounds therefore alleges as follows: 1. On or about the, a Final Judgment was entered against the Defendant, JOHN FOE, in the amount of [amount]. 2. On, Plaintiff forwarded Instructions to Levy to the Sheriff of County, Florida in connection with the Sheriff s office levying upon a owned by the Defendant. 3. Upon receipt of Plaintiff s Instructions for Levy, the Sheriff s office advised Plaintiff that the vehicle may be located inside any building or structure at the Defendant s residence located at [address where property is located]. As a result, the Sheriff s office is requiring a Break Order to levy upon the subject vehicle. 4. The Final Judgment represents the Court s determination of a legal obligation of the Defendant to the Plaintiff. The Defendant may not avoid this legal obligation to Plaintiff by secreting property which may be the subject matter of a levy. The same allows the Defendant to act in defiance of the Final Judgment and to avoid payment of their legal obligation to Plaintiff. 5. If the Court wishes to condition the granting of this Break Order on Plaintiff posting a
small cash bond in the event that there might be a need for repair to the Defendant s enclosure, Plaintiff is willing to post a bond in the amount of $500.00 with the Court for the purposes of this Order being entered. 6. This Motion is made on an Ex-Parte basis because of the easy movability of the vehicle which is the subject matter of this levy. Given the fact that the same can easily be secreted and moved from one location to another and given the actions of the Defendant, it is necessary that this Motion be made without notice to Defendant so as to make certain that Plaintiff has a continuing opportunity to collect the Final Judgment despite the actions of the Defendant. WHEREFORE, Plaintiff, JOHN DOE, respectfully requests this Honorable Court enter a Break Order allowing the Sheriff of County to enter the Defendant s structure and to levy upon the subject vehicle for the reasons above alleged.
IN THE CIRCUIT COURT OF THE 15 TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CIVIL DIVISION CASE NO.: JOHN DOE, v. JOHN FOE, Plaintiffs, Defendant. / STATE OF FLORIDA COUNTY OF DUVAL AFFIDAVIT IN SUPPORT OF EX-PARTE MOTION FOR BREAK ORDER BEFORE ME, the undersigned authority, personally appeared JOHN DOE, who, being by me first duly sworn, deposes as says as follows: 1. Affiant is the Plaintiff. 2. Affiant is authorized to make this Affidavit on behalf of said plaintiff. 3. Affiant has reviewed the file of this matter providing her with personal knowledge of the matters contained herein. 4. Affiant knows and is familiar with the identity and method of preparation of the business records attached to this Affidavit. The business records of Plaintiff upon which this Affidavit was based were made at or near the time of the events recorded therein. The source of the information was an individual or individuals whose business duties involved furnishing this information to Plaintiff. Such business records are kept in the ordinary course of Plaintiff s business to maintain such records. It is a regular practice of Plaintiff s business to maintain such records. The contents of this Affidavit are predicated upon Affiant s examination of such records. 5. On or about, Plaintiff obtained a Final Judgment against Defendant in the amount of [amount].
6. Recently, Plaintiff conducted an asset search as to Defendant and found that Defendant had registered in their name a, VIN#. As follows, Plaintiff sent in Instructions for Levy to the Sheriff of County, Florida on [date], in connection with the Sheriff levying upon the subject vehicle. 7. The Sheriff of County attempted levy on the subject vehicle. The vehicle was not located, however, the Sheriff s office advised that the vehicle may be located inside the building or structure at the Defendant s residence located at [address]. 8. Plaintiff is willing to post a $500.00 cash bond with the Court in connection with any damages that may be done to the Defendant s building or structure in connection with the Sheriff s office gaining entry into same for purposes of levy upon Defendant s aforesaid vehicle. Plaintiff does not anticipate any damages occurring at the premises to the real property and thus this $500.00 amount should be sufficient to pay any such damages Defendant may experience in connection with execution of the Break Order. FURTHER AFFIANT SAYETH NAUGHT. John Doe STATE OF FLORIDA COUNTY OF The foregoing instrument was acknowledged before me, this day of, 2017 by who is personally known to me. Notary Public, State of Florida Notary s Printed Signature My Commission Expires:
IN THE CIRCUIT COURT OF THE 15 TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CIVIL DIVISION CASE NO.: JOHN DOE, v. JOHN FOE, Plaintiffs, Defendant. / ORDER GRANTING PLAINTIFF S EX-PARTE MOTION FOR BREAK ORDER THIS CAUSE came before this Court upon Plaintiff s Ex-Parte Motion for Break Order. The Motion is related to Plaintiff seeking to levy upon a. The Sheriff of County has advised Plaintiff that the subject vehicle may be located inside any building or structure at the Defendant s residence at [address]. Plaintiff has agreed to post a bond if any damage is done to the structure in connection with the Sheriff executing this Break Order by opening the garage door and carrying out the levy of the subject vehicle. Based on the foregoing and the Court being otherwise fully advised in the premises, it is ORDERED AND ADJUDGED as follows: 1. Plaintiff s Ex-Parte Motion for Break Order be and the same is hereby granted. 2. The Sheriff of County, Florida is hereby authorized to enter that certain building or structure located at [address], for purposes of determining if a certain, VIN# is located therein. If so, the Sheriff of County shall levy upon said vehicle pursuant to the Instructions for Levy previously provided to the Sheriff s office by Plaintiff. If after the Sheriff s office gains entry into the building or structure and the Sheriff s office determines that the subject vehicle is not situate inside the building or structure, the Sheriff s office shall return the building or structure to the condition it was in at the time the Break Order was executed.
3. The sole purpose for this Order is to allow the Sheriff of County to levy upon the subject vehicle. No other civil function of the Sheriff s office is permitted by this Order. 4. In consideration of the Court ruling upon this Motion on an Ex-Parte basis, Plaintiff shall post a cash bond in the amount of $500.00 with the Clerk of the Court for purposes of any damages to the aforesaid building or structure as well as any fees or costs incident to the entry and execution of this Break Order. DONE AND ORDERED in Chambers at County, Florida this day of, 2017. cc: Circuit Court Judge
IN THE CIRCUIT COURT OF THE 15 TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CIVIL DIVISION CASE NO.: JOHN DOE, v. JOHN FOE, Plaintiffs, Defendant. / NOTICE OF POSTING $500.00 CASH BOND COMES NOW the Plaintiff, JOHN DOE, and hereby gives notice that Plaintiff has posted a $500.00 cash bond with the Clerk of the Court pursuant to the Court s Order requiring the posting of said bond in connection with the Sheriff levying upon that certain vehicle owned by the Defendant in County, Florida. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by United States Mail this day of, 2017 to Department of the Sheriff of County, Civil Department, [ADDRESS].
IN THE CIRCUIT COURT OF THE JUDICIAL CIRCUIT, IN AND FOR COUNTY, FLORIDA CIVIL DIVISION JOHN DOE, CASE NO. Plaintiff, v. JOHN FOE, Defendant. / BANK OF, Garnishee. / MOTION FOR WRIT OF GARNISHMENT JOHN DOE ( Plaintiff ), by and through the undersigned counsel, moves the Clerk of this Court to issue a Writ of Garnishment against the Garnishee, BANK OF and states that the Plaintiff has obtained a judgment dated [DATE], against the Defendant, JOHN FOE, in the amount of [AMOUNT], which shall accrue post-judgment interest at the legal rate per annum from the date of the judgment for all of which let execution issue. Plaintiff further states that they are not applying for this garnishment to injure the Defendant, JOHN FOE or the Garnishee, but it believes that the Garnishee has in its possession or control, goods, monies, chattels, or effects belonging to the said Defendant, JOHN FOE, and that Plaintiff does not believe that the Defendant, JOHN FOE, has in his possession at the present time, sufficient assets to satisfy the judgment now outstanding in the amount of [AMOUNT], which shall accrue post-judgment interest at the legal rate per annum from the date of the judgment for all of which let execution issue. WHEREFORE, Plaintiff moves that this Honorable Court issue a Writ of Garnishment against BANK OF. who it believes has in its possession sufficient goods, monies, or chattels to satisfy the outstanding final judgment plus post judgment court costs and attorneys fees. DATED this the day of, 2017. [SIGNATURE BLOCK OF ATTORNEY]
IN THE CIRCUIT COURT OF THE 15 TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CIVIL DIVISION CASE NO.: JOHN DOE, v. JOHN FOE, Plaintiffs, Defendant. / and ACME CHEMICALS, INC., Garnishee. / POST-JUDGMENT MOTION FOR CONTINUING WRIT OF GARNISHMENT OF WAGES/SALARY AS TO JUDGMENT DEBTOR, JOHN FOE Judgment Creditor, JOHN DOE, by and through their undersigned counsel moves this Court to issue a Continuing Writ of Wages/Salary Garnishment against the Garnishee, ACME CHEMICALS, INC., and states the following: BACKGROUND 1. The Judgment Creditor holds an unsatisfied judgment in this case dated [DATE] against the Judgment Debtor, JOHN FOE, in the amount of [AMOUNT]. 2. JOHN FOE is employed by the GARNISHEE, he is not indigent and has failed to satisfy the judgment in any amount. 3. The Judgement Creditor is not applying for this garnishment to injure JOHN FOEbut believes that the Garnishee owes and will continue to owe JOHN FOE wages, salary, or commissions, by virtue of JOHN FOE S employment with the Garnishee for which {JKOENIG/201620.0001/W8047019_1}
the Judgment Creditor is entitled. 4. The Judgment Creditor is entitled to a Writ of Continuing Wages/Salary Garnishment requiring the Garnishee, ACME CHEMICALS, INC., to retain and pay over to the Judgment Creditor the lesser of 25% of JOHN FOE S, net income or thirty (30) times the minimum wage pursuant to Florida Statute, Federal and Florida Law. Under Florida law, the Writ of Garnishment also includes amounts payable as commissions. Baker v. Storfer, 51 So. 3d 652 (Fla. 4 th DCA 2011). 5. The Judgment Creditor does not believe that JOHN FOE has in his possession at the present time, sufficient assets to satisfy the final judgment balance now outstanding in the amount of [amount], together with post-judgment interest at the rate set by statute. WHEREFORE, the Judgment Creditor, JOHN DOE, moves this Honorable Court to issue a Continuing Writ of Wages/Salary Garnishment against Garnishee, ACME CHEMICALS, INC., who, the Judgment Creditor believes owes and will continue to owe JOHN DOE, wages and/or salary and/or commissions, for which the Judgment Creditor is entitled until such time as the judgment is fully satisfied. DATED this the day of, 2017. SIGNATURE BLOCK OF ATTORNEY {JKOENIG/201620.0001/W8047019_1}
INTERROGATORIES 1. Please state your full name, any other names you have been known by, date of birth, social security number, permanent residence address, length of time at this address and telephone number. 2. If you are married, please state the name, address, age, present occupation and place of employment of your spouse. 3. Do you own, rent or have any other interest (including equitable and future interests, interests in estates by the entirety, joint ownership, community property, life estates and rights and powers exercisable for your own benefit) in any real property in this state or elsewhere, including your residence? If so, then for each parcel of real property owned by you or in which you have any other nonleasehold interest, please state the address and legal description, the nature of your interest in the property, the date acquired, the names and addresses of mortgage holders, the balance due on each mortgage, the amount of the monthly payment on each mortgage and the assessed tax value or fair market value of the property. For each piece of property rented by you, please state the name and address of the landlord, amount of monthly rental and amount of security deposit, if any. 1
4. Do you own or have any interest in any tangible personal property, including but not limited to, motor vehicles, boats, airplanes, jewelry, precious metals, art treasures, stamp collections, libraries, furniture, appliances, electronic equipment (such as stereos, televisions, video recorders, computers), clothing, garden equipment, tools, sporting equipment, business equipment, farm equipment, horses, livestock or other animals? If so, then for each item of tangible personal property, please describe the item and indicate its location, the approximate fair market value, the nature of your interest, the name and address of any lienholder, and the amount due on each lien. 2
5. Do you own, hold or have any interest in any intangible property, including but not limited to, stocks, bonds, coupons, notes, mortgages, drafts or other securities or instruments, negotiable or nonnegotiable, patents, copyrights, trademarks, trade secrets, inventions, licenses or franchises? If so, then for each such item, please indicate the nature of the item, the amount of any payments, including royalties, due to you, the name and address of the person or entity making such payments, the approximate fair market value and the nature of your interest. 3
6. Do you have any deposits, accounts or shares in any banking institutions, savings and loan associations, thrift associations, building and loan associations, homestead associations or other depositories, including but not limited to, savings accounts, retirement accounts, money market accounts, certificates of deposit or checking accounts? If so, please state, for each such deposit, account or share, the name and address of the depository, the type of deposit, account or share, the identification or account number, the nature of your interest, the approximate present balance and the highest balance during the period commencing one year after the date of service of process upon you in this case. 7. Have any deposits, accounts or shares in which you had any interest been closed within one (1) year after the date of service of process upon you in this case? If so, please state, for each such deposit, account or share, the name and address of the depository, the type of deposit, account or share, the identification or account number and the date closed. 4
8. Do you, alone or with any other person, have any property in or maintain any safe deposit boxes? If so, please state, for each safe deposit box, where it is located, in whose name it is listed, its identification number and its present contents. 9. Are there any insurance policies, including but not limited to, annuities, of which you are either a beneficiary or in which you have any interest? If so, then for each such policy, please state the name and address of the insurer, the nature of your interest, the face amount of the policy, cash surrender value and the names and addresses of the beneficiaries. 5
10. Do you have any interest in any pension, profit sharing or other retirement plans, from either a government, corporation or other source? If so, then for each such plan, please indicate the name and address of the source, the name and address of the beneficiary, the nature of your interest, the date that benefits become due, the amount of the benefits per month, and the present cash surrender value of the fund. 11. Do you have any vested or contingent future interest (e.g. remainder, reversion) in any property, real or personal? If so, please state, for each item of property, the type and location of the property, (if realty, the address and legal description), the nature of your interest, the names and addresses of mortgage or lienholders, the balance due on each mortgage or lien, and the assessed tax value or fair market value. 6
12. Do you have any interest in any Will or do you expect to receive anything by inheritance? If so, please state, for each Will or expected inheritance, from whom and the approximate value. 7
13. Do you have any claims, including accounts receivable, or liens against any other person, entity or property? If so, please describe, for each claim or lien, the amount, the reason for the claim or lien, the name and address of any person or entity subject to the claim or lien and the location of the property subject to the claim or lien. 8
14. Is anyone holding any property, real or personal, tangible or intangible, in which you have any type of interest, in trust, for you or in any other way on your behalf? If so, for each item of property, please describe the property so held, the nature of your interest, the name and address of the person or entity holding the property and the reason why the property is being so held. 9
15. Have you received, within the present fiscal year or the prior fiscal year, any bonuses, dividends, loans or other withdrawals from your employer or business, in addition to your salary? If so, for each withdrawal, please state the date, amount and reason for such withdrawal. If so, has any relative of yours received since the earlier of six (6) years from today's date, or one (1) year prior to service of process against you in this lawsuit, anything from any of your places of employment? If so, for each receipt, please state the name and address of the relative, the date, amount and reason for such receipt. 16. Do you have any income or any source of income, such as alimony, not previously disclosed by you? in your answers to these interrogatories? If so, please state the nature of such income, the name and address of the payor and the monthly amount. 1 0
17. Do you have any interest in any corporations or partnerships as manager, stockholder, agent, director, officer, partner (general or limited) or otherwise? If so, please state the name and address of the corporation, and the nature of your relationship with the corporation. 1 1
18. For each item of property, real or personal, including cash on hand, which has not been previously disclosed by you in your answers to these interrogatories, and in which you have any interest, present or future, or which is being held for your benefit by any person or entity, including a trustee or nominee, please describe such property, the location of the property, the nature of your interest, the approximate fair market value of the property, the name and address of any mortgagee or lienholder, and the amount due upon each mortgage or lien. 19. Have you made any gift, conveyance or otherwise transferred any interest in any property within one (1) year after service of process against you in this case? If so, please state, for each transfer, the date, the item transferred, the nature of the interest transferred, the consideration received by you and the name and address of the transferee. 1 2
20. Did there ever exist books, records, statements, cancelled checks or other tangible materials relating to any of your assets, liabilities, income or expenses for any time(s) commencing with the date one (1) year prior to service of process against you in this case? If so, please state the name and address of all person(s) or entity(ies) who have possession of such materials. If, however, any of these materials have been destroyed, lost, or are otherwise unavailable, please state the date these materials became unavailable, the name and address of all person(s) or entity(ies) responsible for the unavailability and the reason why such materials were made unavailable. UNDER PENALY OF PERJURY I SWEAR THAT THE FOREGOING ANSWERS ARE TRUE AND CORRECT. FURTHER AFFIANT SAYETH NAUGHT. STATE OF FLORIDA COUNTY OF PALM BEACH Affiant The foregoing instrument was acknowledged before me this the day of July, 2016 by, who is personally known to me or who has produced as identification. Notary Public State of Florida 1 3
DOCUMENTS AND THINGS TO BE PRODUCED 1. All of your financial, business, bank and property records and all other papers, passbooks, record books and books of account which tend to disclose the extent and nature of all financial interests, property and property rights you own or owned, and the location(s) thereof at any time from January 1, 2015 to the present. 2. All passbooks with respect to all savings accounts, checking accounts, and loan association accounts, you owned or owned by any other entity in which you had or have an interest and/or signature power at any time from January 1, 2015 to the present. 3. All check books, check stubs, canceled checks, bank statements, and electronically stored bank history, concerning any bank account that was or is you owned or on which the you had or have signature authority, or that was or is owned by any other entity in which you have or had an interest at any time from January 1, 2015, through the present. 4. The deeds, or copies thereof, to all real property you owned or owned by any other entity in which you had or have an interest at any time from January 1, 2015, through the present. 5. All corporate securities (stocks, bonds, funds, etc.) you owned and all evidences of investments you owned or owned by any other entity in which you had or have an interest at any time from January 1, 2015, through the present. 6. The latest available balance sheets and other most recent financial statements or information and reports of every kind in your possession with respect to or any and all other investments and/or business enterprises of whatever nature in which you had or have an interest at any time from January 1, 2015, through the present.
7. Your accounts receivable ledger or other record which sets forth the names and addresses of all personal or business enterprises that have been or are indebted to you or any and all other investments and/or business enterprises of whatever nature in which you had or have an interest, including the amount of such indebtedness, together with copies of contracts or accounts receivable or other records showing the amount of any on-going or current work, the amount to be received, and other information to show cash flow, anticipated profit, or related information at any time from January 1, 2015, through the present. 8. Copies of your federal income tax returns plus any other investment or business entity in which you possessed or possesses any ownership interest; and copies of any other documents you filed with the United States Internal Revenue Service, Department of Treasury, and Florida Department of Revenue at any time from January 1, 2013, through the present. 9. All financial statements or reports, including any schedules or attachments thereto, profit and loss statements, and balance sheets prepared by and/or for you relating to your financial affairs at any time from January 1, 2015, through the present. 10. Any settlement agreements you entered into relating to any court action, foreign or domestic, whether actual, threatened, or contemplated, including actions in general civil and bankruptcy courts at any time from January 1, 2015, through the present. 11. All documents relating to the satisfaction or discharge of any debts, encumbrances, liens, judgments, awards or settlement agreements, whether foreign or domestic, to which you were a party at any time from January 1, 2015, through the present.
12. Copies of the front of all credit cards, charge cards, or debit cards which you possessed, maintains and/or controlled at any time from January 1, 2015, through the present. 13. The title certificates, registration certificates, bills of sale, and other evidences of ownership with respect to any of the following described personal property owned by you or owned by any other entity in which you had or have an interest, from January 1, 2015, through the present: (a) Motor vehicles and/or aircraft of any type; (b) Commercial, business, trade or construction equipment of any type; (c) Boats, trailers, watercraft, cruisers, airplanes or other vessels of any type; (d) Inventory of any stock of goods or equipment of any type; (e) Patents, trademarks or copyrights; (f) Stocks or bonds of any type at any time; (g) cell phones, tablets, computers, laptops, televisions, stereos. 14. All appraisal reports which you have received on any real or, tangible or intangible, personal property at any time from January 1, 2015, through the present. 15. All documents reflecting ownership in or conveyance of an interest in any type of season ticket subscriptions you possessed or any and all other entities of whatever nature in which you had or have an interest. 16. All of your records pertaining to the transfer of any money or property interest or financial interests you made or any and all other entities of whatever nature in which you had or have an interest since January 1, 2015. 17. All property or personal property leases in which you, or any and all other entities of whatever nature in which you had or have an interest, was or is named as lessor(s) or lessee(s) at any time from January 1, 2015, through the present.
18. All real property or personal property mortgages in which you, or any and all other entities of whatever nature in which you had or have an interest, was or is named as mortgagee or mortgagor. 19. All your, or any and all other entities of whatever nature in which you had or have an interest, that had or have contracts or agreements for services and/or goods with any other person(s) and/or company(s) at any time from January 1, 2015, through the present. 20. All financial statements, loan or credit applications you or any and all other entities of whatever nature in which you had or have an interest completed, contribute to or submitted at any time from January 1, 2015, through the present. 21. All documents concerning, relating or referring to, or pertaining to any factoring or other financing arrangement you or any and all other entity of whatever nature in which you had or have an interest, at any time from January 1, 2015, through the present. 22. Any inventory of personal property that you or any and all other entity of whatever nature in which you had or have an interest has maintained or may maintain for insurance or other purpose at any time from January 1, 2015, through the present. 23. Any business or occupational license(s) that you, or any and all other entities of whatever nature in which you had or have an interest, has had or may have and/or maintains at any time from January 1, 2015, through the present. 24. Any franchise, patent or copyright certificates that you, or any and all other entities of whatever nature in which you had or have an ownership interest, has or had at any time from January 1, 2015, through the present. 25. Copies of any and all promissory notes or other forms of indebtedness under which you, or any and all entities of whatever nature in which you had or have an interest, has been
or is liable solely or with any other person or entity at any time from January 1, 2015, through the present. 26. Copies of any and all accounts, debts, receivables or notes owed to you, or any and all other business enterprises of whatever nature in which you had or have an interest, at any time from January 1, 2015, through the present. 27. Copies of any and all outstanding accounts receivable, which you contend that you are or have been obligated to pay to third-persons at any time from January 1, 2015, through the present. 28. All insurance policies insuring loss to any property, real or personal, which you, or any and all other entities of whatever nature in which you had or have an interest, owned or owns alone or jointly with any other entity or person at any time from January 1, 2015, through the present. 29. All documents disclosing the location of any cash held by you. 30. All documents showing an inventory of equipment, furniture, computers, and similar tangible assets. 31. All documents showing the bank records where customer deposits are being held. 32. All agreements between you and your customers and clients.