09/07/2007 201 Debtor Pro Mold's Inc.'s, First Set of Interrogatories and Requests for Production of Documents to John Murphy, III Revocable Trust No. 1, filed by Pro Mold, Inc.. (Kennedy, Ellen) (Entered: 09/07/2007)
---------
Doc 201
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 P. MURPHY, III REVOCABLE TRUST NO. 1
Comes the Debtor, Pro Mold, Inc., by counsel,…
[…]
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 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. 3: 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. 4: 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.
INTERROGATORY NO. 5: Please identify each and ever person that you intend to call as a witness at the hearing of the Motion for Relief From Automatic Stay Filed By Pro Plas, LLC, John P. Murphy III Revocable Trust No. 1, 10315 LLC, and John Murphy and describe the substance of their anticipated testimony.
INTERROGATORY NO. 6: Please identify each and every exhibit that you intend to use as evidence at the hearing of the Motion for Relief From Automatic Stay Filed By Pro Plas, LLC, John P. Murphy III Revocable Trust No. 1, 10315 LLC, and John Murphy.
INTERROGATORY NO. 7: Please identify each and every person you intend to call as an expert witness at the hearing on the Motion for Relief From Automatic Stay Filed By Pro Plas, LLC, John P. Murphy III Revocable Trust No. 1, 10315 LLC, and John Murphy 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. 3: Please produce any and all documents referred to, relied upon or referenced by you in the Motion for Relief From Automatic Stay Filed By Pro Plas, LLC, John P. Murphy III Revocable Trust No. 1, 10315 LLC, and John Murphy.
REQUEST NO. 4: Please produce any and all documents you intend to use as evidence in support of the Motion for Relief From Automatic Stay Filed By Pro Plas, LLC, John P. Murphy III Revocable Trust No. 1, 10315 LLC, and John Murphy.
REQUEST NO. 5: Please produce a statement of account for each and every loan referenced or referred to in the Motion for Relief From Automatic Stay Filed By Pro Plas, LLC, John P. Murphy III Revocable Trust No. 1, 10315 LLC, and John Murphy.
REQUEST NO. 6: Please produce all documents regarding the indebtedness asserted in the Motion for Relief From Automatic Stay Filed By Pro Plas, LLC, John P. Murphy III Revocable Trust No. 1, 10315 LLC, and John Murphy, including but not limited to all documents regarding payments made on all loans claimed due to you by Pro Mold, Inc. and the amounts currently due on those loans.
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, Esq.
Timothy A. West, Esq.
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 |
