122.

Sample Request for Production of Documents

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA, Plaintiff, v. CIVIL ACTION NO. 93C 1794 JUDGE GRADY GHEORGHI NEDIALKOV (also known ) MAGISTRATE JUDGE LEFKOW as GEORGE NEDIALKOV), and AMES NEDIALKOV, Defendants. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT JAMES NEDIALKOV To: Defendant James Nedialkov c/o Gregory J. Schlesinger, Esq. 180 N. La Salle Street Chicago, Illinois 60601 Pursuant to Rule 34 of the Federal Rules of Civil Procedure, plaintiff United States requests that the defendant produce the following described documents for inspection and copying by the United States at a time and place to be mutually agreed upon by the parties within thirty days of service thereof. This request is continuing in nature, and in the event you become aware of or acquire in your possession, custody or control, additional responsive documents, you are asked promptly to produce such additional documents for inspection and copying. DEFINITIONS For the purposes of this request for production, the following definitions control: "Documents" are documents, records, books, papers, contracts, memoranda, invoices, correspondence, notes, studies, reports, photographs, drawings, charts, maps, graphs, other writings, recording tapes, recording discs, mechanical or electronic information or recording elements, and any other "documents" as defined in Rule 34, Fed. R. Civ. P. If a document has been prepared in several versions, or if additional copies have made which are not identical or are no longer identical by reason of subsequent notation or marking of any kind, each nonidentical copy is a separate document. "Relating" means referring to, being evidence of, memorializing, or concerning in any way all or any portion of the specified facts or contentions. REQUESTS Income Tax Returns, 1991 through the present. Bank and Savings and Loan Associations or Credit Union Statements, 1991 and 1992, including: Any and all Checking Accounts; Any and all Savings Accounts; Any and all Certificates of Deposit. Any and all IRA Accounts; Any and all investment funds; Any and all retirement accounts; Records of any repairs, maintenance or improvements to 1241 West Loyola since you purchased the property including invoices, receipts, canceled checks and any other documents which refer or relate to any such repairs, maintenance or improvements. Checks for any expenses related to eviction proceedings or any other expenses related to the business of renting apartments (including attorneys' fees) for the property located at 1241 W. Loyola. Documents relating to any securities you own. Ownership documents for all real property you own. Any financial statement including any application you have produced for any purpose in the since January 1, 1991. Inventory of your personal and business property prepared in since January 1, 1991. Appraisals of all real property in which you have an ownership interest. Written instruments recording debts you owe or money owed to you since January 1, 1991. The response to this request should include all documents including settlement or closing papers reflecting mortgages, financing and refinancing of all property owned by you. Documents involving financial transactions with any family members since January 1, 1991. Books and Records of your income and business affairs since January 1, 1991. Documents relating to trusts of which you are the beneficiary. Include all documents reflecting your initial purchase of 1241 W. Loyola. Ownership documents for all assets worth at least $2,000.00. 15.All documents which you reviewed or consulted or mentioned in responding to Plaintiffs First Set of Interrogatories. Plaintiff requests that Defendant permit Plaintiff to enter the apartment building at 1241 West Loyola in Chicago, Illinois to enter and photograph and/or videotape the building, including the office and various units therein. Plaintiff will confer with Defendants through counsel to determine a mutually agreeable time for making such inspection. Upon such agreement, Plaintiff will issue a subpoena to certain current tenants as provided in Fed. R. Civ. P. 34(c) and Fed. R. Civ. P. 45. Absent such agreement, Plaintiff will issue such subpoenas for a time convenient to Plaintiff. Respectfully submitted, __________________________________ Isabelle M. Thabault Barbara Kammerman Valerie O'Brian Attorneys Housing and Civil Enforcement Section Civil Rights Division United States Department of Justice P.O. Box 65998 Washington, D.C. 20035-5998 (202)514-1006 CERTIFICATE OF SERVICE I hereby certify that on the ____ day of April, 1993, I mailed a copy of the foregoing Plaintiff's First Request for Production of Documents to counsel for defendant, Gregory J. Schlesinger, 180 N. LaSalle Street, Suite 1708, Chicago, Illinois 60601. ________________________ Barbara Kammerman Attorney U.S. Department of Justice Washington, D.C. [cited in Civil Rights Resource Manual 60]