Documents Requested
- All XTS Cloud LLC digital company files that were stored in Google Business Drive prior to April 16, 2021.
- All XTS Cloud LLC digital email records from May 31, 2017 to April 16th, 2021.
- Copies of any and all documents, records or writings made in the ordinary course of business concerning the subject matter to this action.
- Copies of Berenson’s transcripts from any institution of higher education, i.e college, university.
- Copies of Berenson’s 2018 – 2020 tax returns.
- Copies of Berenson’s personal bank statements, covering the most recent 36 months.
- A full inventory of the XTS Cloud inventory assets, and general assets that Berenson has in his possession, in addition to proof that the assets have not been sold, destroyed, and that they are being stored in a bonded facility with appropriate insurance and commercial licensing.
- Copies of all public records pertaining to any bankruptcies, lawsuits, or criminal matters that Berenson has been party to over the past 10 years.
- Proof that the XTS Cloud LLC assets that are in Berenson’s possession are being stored in a commercial facility with a proper business insurance policy covering the inventory for a minimum of $70,000.
- Copies of all of Berenson’s 1099-B tax documents pertaining to the 2020 tax year.
- Copies of Berenson’s two most recent pay stubs.
- Any documentation at all upon which you intend to base in whole, or in part, any defense to the allegations set forth in the Plaintiff’s Complaint.
- Evidence of Berenson’s ownership in XTS Cloud LLC after Berenson’s chapter 7 bankruptcy discharge.
- Evidence that Berenson properly disclosed his ownership in XTS Cloud LLC during his chapter 7 bankruptcy proceedings.
- A full list of the assets that were disclosed during Berenson’s most recent chapter 7 bankruptcy.
- Documentation showing that Berenson was an authorized signatory on the Bank of America XTS Cloud LLC business checking account.
- Documentation showing that XTS Cloud LLC was ‘fired’ by TechChomm solutions and/or Lifespire during April 2021, in addition to any official documents showing that the business relationship and contract were cancelled and the reasoning for the termination.
- All documents relating to outstanding and/or delinquent personal IRS tax liabilities owed by Berenson.
- Copies of Berenson’s personal medical records covering the past 10 years.
- All documents and/or communications relating to any facts on the basis of which it is asserted that the conduct of the Plaintiff contributed to the Defendant’s actions.
- Any and all documents of any nature whatsoever referred to in Defendant’s Answers to Plaintiff’s Complaint.
- All passwords and logins relating to any digital accounts owned by XTS Cloud LLC, including Shipstation.com, Google Domains, Google Drive, Google Business, Gmail for Business.
- Any and all documents and communications substantiating any defense to Plaintiff’s cause of action.
- List of all addresses where Defendant lived within the past 10 years, including full addresses, dates, and proof of residence for each location
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