PLAINTIFFS REQUEST FOR PRODUCTION OF DOCUMENTS OR THINGS

July 11, 2023

EIGHTH JUDICIAL DISTRICT COURT

IN AND FOR CLARK COUNTY, STATE OF NEVADA

 

CHARLIE O. EZUMA                                     §

Plaintiff,                                                  §

§

v.                                                              §     Case No. A-21-832654-C Dept No. 29

§

JASON BERENSON                                         §

Defendant.                                              §

 

PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS OR THINGS

 

Propounding Party: CHARLIE O. EZUMA

Responding Party: JASON BERENSON

Department Number: 29

 

To Defendant Jason Berenson and to his attorney of record:

Plaintiff, Charlie O. Ezuma, demands that you produce and permit the inspection and copying by or on behalf of himself of the documents and tangible things in the categories described below.

Production may be satisfied by serving by mail to Insert Address, legible copies of the items to be produced, accompanied by a written affidavit stating that they are true copies, no more than thirty-five (35) days after service of this Request. If any document is two-sided, a copy of both front and back is required. Originals may instead be produced for inspection and copying by Plaintiff at Insert Address on Insert Date at Insert Time.

 

CATEGORIES OF DOCUMENTS OR THINGS TO BE PRODUCED

1.      All XTS Cloud LLC digital company files that were stored in Google Business Drive prior to 04/16/2021;

2.      All XTS Cloud LLC digital email records from 05/31/2017 to 04/16/2021;

3.      Copies of any and all documents, records or writings made in the ordinary course of business concerning the subject matter of this action;

4.      Copies of Defendant’s transcripts from any institution of higher education i.e. college or university;

5.      Copies of Defendant’s tax returns from 2018 to 2020;

6.      Copies of Defendant’s personal bank statements, covering the most recent 36 months;

7.      A full inventory of the XTS Cloud inventory assets, and general assets that Defendant 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;

8.      Copies of all public records pertaining to any bankruptcies, lawsuits, or criminal matters that Defendant has been party to over the past 10 years;

9.      Proof that the XTS Cloud LLC assets that are in Defendant’s possession are being stored in a commercial facility with a proper business insurance policy covering the inventory for a minimum of $70,000.00;

10.  Copies of all of Defendant’s 1099-B tax documents pertaining to the 2020 tax year;

11.  Copies of Defendant’s two most recent pay stubs;

12.  Any documentation at all upon which Defendant intends to base in whole, or in part, any defense to the allegations set forth in Plaintiff’s Complaint;

13.  Evidence of Defendant’s ownership in XTS Cloud LLC after Defendant’s Chapter 7 bankruptcy discharge;

14.  Evidence that Defendant properly disclosed his ownership in XTS Cloud LLC after Defendant’s Chapter 7 bankruptcy proceedings;

15.  A full list of the assets that were disclosed during Defendant’s most recent Chapter 7 bankruptcy proceedings;

16.  Documentation showing that Defendant was an authorized signatory on the Bank of America XTS Cloud LLC business checking account;

17.  Documentation showing that XTS Cloud LLC was ‘fired’ by TechComm Solutions and/or Lifespire in April 2021, in addition to any official documents showing that the business relationship and contract were cancelled and the reasoning for the termination;

18.  All documents relating to outstanding and/or delinquent personal IRS tax liabilities owed by Defendant;

19.  Copies of Defendant’s personal medical records covering the past 10 years;

20.  All documents and/or correspondence relating to any facts on the basis of which it is asserted that the conduct of Plaintiff contributed to Defendant’s actions;

21.  Any and all documents of any nature whatsoever referred to in Defendant’s Answer to Plaintiff’s Complaint;

22.  All passwords and logins relating to any digital accounts owned by XTS Cloud LLC, including shipstation.com, Google domains, Google Drive, Google Business, and Gmail for Business;

23.  Any and all documents and communication substantiating any defense to Plaintiff’s cause of action;

24.  List of all addresses where Defendant lived within the past 10 years, including full addresses, dates and proof of residence for each location.

 

Dated:

 

 

Respectfully Submitted,

______________________________

Charlie O. Ezuma

9745 Grand Teton Drive, 2104

Las Vegas, Nevada 89166

Insert Phone Number

Insert Email

 

VERIFICATION

I, Charlie O. Ezuma, being duly sworn depose and say that I am the Plaintiff in the above entitled action, that I have read the foregoing Request for Production of Documents or Things and know the contents thereof. That the same is true of my own knowledge except as to those matters and things stated upon information and belief, and as to those things, I believe them to be true.

_________________________________

(Sign in the presence of a Notary Public)

Sworn to and subscribed before me this _____ day of ____________________, 2021.

______________________________

Notary Public

________________________________________

(Printed name of Notary Public)

My Commission Expires: ____________________

 

CERTIFICATE OF SERVICE

            I hereby certify that a true and correct copy of the foregoing document was sent on the (Date) day of (Month) (Year) by regular U.S. mail, by facsimile, or certified mail, return receipt requested, to the following parties or attorneys of record:

            Leah Martin, Esq., Attorney at Law

            Nevada Bar No. 7982

            Kevin Hejmanowski, Esq.

            Nevada Bar No. 10612

            LEAH MARTIN LAW

            3100 W Sahara Ave. #202

            Las Vegas, Nevada 89102

            Telephone: (702) 420-2733

            Facsimile: (702) 330-3235

            lmartin@leahmartinlv.com

            khejmanowski@leahmartinlv.com

 

Dated:

 

 

Respectfully Submitted,

______________________________

Charlie O. Ezuma

9745 Grand Teton Drive, 2104

Las Vegas, Nevada 89166

Insert Phone Number

Insert Email

 

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