09/07/2007 204 Debtor Pro Mold, Inc.'s First Set of Interrogatories and Requests for Production of Documents to John Murphy, filed by Pro Mold, Inc.. (Kennedy, Ellen) (Entered: 09/07/2007)
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Doc 204
IN RE:
Case No. 07-50935
Judge William S. Howard
Chapter 11
PRO MOLD, INC.
Debtor.
DEBTOR PRO MOLD, INC.’S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO JOHN MURPHY
Comes the Debtor, Pro Mold, Inc., by counsel,…
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INTERROGATORIES
INTERROGATORY NO. 1: Please state the name, title and business address of the person or persons answering these Interrogatories and Requests for Production of Documents.
INTERROGATORY NO. 2: Please state whether, since December 31, 2005, you removed or otherwise took possession of any furniture, computers or any other property belonging to Pro Mold, Inc., its officers, directors, agents or employees. If you answer in the affirmative, describe with specificity the items that you removed or took possession of and the basis that you were entitled to do so.
INTERROGATORY NO. 3: Please state whether, since December 31, 2005, you copied, deleted, destroyed or otherwise altered any electronic information found on any computer used by Pro Plas, LLC in the course of its business. If you answer in the affirmative, please describe with specificity, the computer or computers you used and the date you copied, deleted, destroyed or otherwise altered such electronic information.
INTERROGATORY NO. 4: Please identify each and every person you intend to call as a witness at the hearing of the Motion By the Murphy Entities for Appointment of a Chapter 11 Trustee and describe the substance of their anticipated testimony.
INTERROGATORY NO. 5: Please identify each and every exhibit that you intend to use as evidence at the hearing on the Motion By the Murphy Entities for Appointment of a Chapter 11 Trustee.
INTERROGATORY NO. 6: Please identify each and every person you intend to call as an expert witness at the hearing on the Motion By the Murphy Entities for Appointment of a Chapter 11 Trustee and for each such expert, state as follows:
A. The name, educational background, qualifications, and curriculum vitae of the expert;
B. The subject matter upon which each such expert is expected to testify;
C. The substance of the facts and opinions to which each expert is expected to testify; and
D. A summary of the grounds for any and all opinions held by each such expert.
REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: Please produce any and all documents referred to, relied upon or referenced by you in the Motion By the Murphy Entities for Appointment of a Chapter 11 Trustee.
REQUEST NO. 2: Please produce any and all documents to you intend to use as evidence in support of the Motion By the Murphy Entities for Appointment of a Chapter 11 Trustee.
REQUEST NO. 7: Please produce any and all communications, written or otherwise, between you and the Debtor from December 31, 2005 through the present.
REQUEST NO. 8: Please produce any and all communications between you and any third party regarding the Debtor, its assets, liabilities, financial condition, business operations, pending litigation by or against the Debtor, any financing or proposed financing by the Debtor and any sale or proposed sale of assets or equity of the Debtor.
FOWLER MEASLE & BELL PLLC
/s/ Ellen Arvin Kennedy
Ellen Arvin Kennedy
Timothy A. West
300 West Vine Street, Suite 600
Lexington, KY 40507-1660
(859) 252-6700
(859) 255-3735 fax
EAKennedy@FowlerLaw.com
Twest@FowlerLaw.com
ATTORNEYS FOR DEBTOR
CERTIFICATE OF SERVICE
I hereby certify that the foregoing was served this the 7th day of September, 2007, electronically in accordance with the method established under this Court’s CM/ECF Administrative Procedures and Standing Order dated July 25, 2002 upon all parties in the electronic filing system in this case.
/s/ Ellen Arvin Kennedy
ATTORNEYS FOR DEBTOR |
