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Matthew D. Francis
Nevada Bar No. 6978
mfrancis@bhfs.com
Arthur A. Zorio
Nevada Bar No. 6547
azorio@bhfs.com
BROWNSTEIN HYATT FARBER SCHRECK, LLP
5371 Kietzke Lane Reno, NV 89511
Telephone: 775.324.4100
Facsimile: 775.333.8171
Attorneys for JED MARGOLIN
IN THE UNITED STATES
BANKRUPTCY COURT
FOR THE DISTRICT OF NEVADA
Case No. BK-N- I 6-50644-BTB
Adversary No. 17-05016-BTB
In Re JAZI GHOLAMREZA ZANDIAN,
Debtor.
FRED SADRI, AS TRUSTEE FOR THE STAR LIVING TRUST, DATED APRIL 14, 1997; RAY KOROGHLI AND SATHSOWI T. KOROGHLI, AS MANAGING TRUSTEES FOR KOROGHLI MANAGEMENT TRUST,
Plaintiffs,
V.
JED MARGOLIN; JAZI GHOLAMREZA ZANDIAN; and all other parties claiming an interest in real properties described in this action,
Defendants.
PATRICK CANET,
Counterclaimant,
V.
FRED SADRI, INDIVIDUALLY AND AS TRUSTEE FOR THE STAR LIVING TRUST; RAY KOROGHLI, INDIVIDUALLY; RAY KOROGHLI AND SATHSOWI T. KOROGHLI, AS MANAGING TRUSTEES FOR
KOROGHLI MANAGEMENT TRUST,
Counter-Defendants.
PATRICK CANET,
Cross-Claimant,
V.
JED MARGOLIN,
Cross-Defendant.
DEFENDANT JED MARGOLIN'S FIRST SET OF REQUESTS FOR PRODUCTION TO PATRICK CANET
Pursuant to Rule 34 of the Federal Rules of Civil Procedure, Defendant Jed Margolin ("MARGOLIN") hereby requests that Counterclaimaint/Cross-Claimant Patrick Canet ("CANET") serve responses and documents in response to the following Requests within thirty (30) days of service hereof. These Requests are considered continuing and therefore CANET is required to supplement his responses and document production whenever he obtains different or additional knowledge, information, belief or documents relative to these Requests.
I. DEFINITIONS AND GUIDELINES
MARGOLIN incorporates by reference the Definitions and Guidelines contained in his First Set of Interrogatories to Plaintiffs.
II. REQUESTS FOR PRODUCTION
REQUEST NO. 1:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications between You and ZANDIAN Relating To this adversary proceeding, the subject matter of this adversary proceeding, and/or the FRENCH ACTION,
REQUEST NO. 2:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications between You and SADRI Relating To this adversary proceeding, the
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subject matter of this adversary proceeding, and/or the FRENCH ACTION.
REQUEST NO. 3:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications between You and RAY KOROGHLI Relating To this adversary proceeding, the subject matter of this adversary proceeding, and/or the FRENCH ACTION.
REQUEST NO. 4:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications between You and SATHSOWI T. KOROGHLI Relating To this adversary proceeding, the subject matter of this adversary proceeding, and/or the FRENCH ACTION,
REQUEST NO. 5:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications between You and KMT Relating To this adversary proceeding, the subject matter of this adversary proceeding, and/or the FRENCH ACTION.
REQUEST NO. 6:
Produce any and all contracts or agreements You have with any Person(s) Relating To the FRENCH ACTION, Your Chapter 15 Petition, Your Counterclaim, and/or Your Cross-Claim.
REQUEST NO. 7:
Produce any and all contracts or agreements You have with ZANDIAN Relating To the FRENCH ACTION, Your Chapter 15 Petition, Your Counterclaim, and/or Your Cross-Claim.
REQUEST NO. 8:
Produce any and all contracts or agreements You have with SADRI Relating To the FRENCH ACTION, Your Chapter 15 Petition, Your Counterclaim, and/or Your Cross-Claim.
REQUEST NO. 9:
Produce any and all contracts or agreements You have with RAY KOROGHLI Relating To the FRENCH ACTION, Your Chapter 15 Petition, Your Counterclaim, and/or Your Cross-Claim.
REQUEST NO. 10:
Produce any and all contracts or agreements You have with SATHSOWI T. KOROGHLI
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Relating To the FRENCH ACTION, Your Chapter 15 Petition, Your Counterclaim, and/or Your Cross-Claim.
REQUEST NO. 11:
Produce any and all contracts or agreements You have with KMT Relating To the FRENCH ACTION, Your Chapter 15 Petition, Your Counterclaim, and/or Your Cross-Claim.
REQUEST NO. 12:
Produce all Documents, Communications, and Writings Relating To all actions You have taken anywhere in the world to collect the judgment against ZANDIAN that resulted from the FRENCH ACTION.
REQUEST NO. 13:
Produce all Documents, Writings, and Communications that You received from, or sent to, Bank Melli in the FRENCH ACTION.
REQUEST NO. 14:
Produce all Documents, Communications, and Writings which discuss or show why
You waited approximately 18 years after You obtained Your Judgment against
ZANDIAN in the FRENCH ACTION to attempt to satisfy Your Judgment against
ZANDIAN in Nevada.
REQUEST NO. 15:
Produce any and all agreements and contracts You have with ZANDIAN relating to the recovery or acquisition of any real property that is the subject of this adversary proceeding.
REQUEST NO. 16:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications that support Your FIRST CROSS CLAIM.
REQUEST NO. 17:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications that support paragraph 67 of Your FIRST CROSS CLAIM.
REQUEST NO. 18:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications that support paragraph 68 of Your FIRST CROSS CLAIM.
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REQUEST NO. 19:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications that support paragraph 69 of Your FIRST CROSS CLAIM.
REQUEST NO. 20:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications that support Your SECOND CROSS CLAIM.
REQUEST NO. 21:
Produce all Documents and things Relating To any non-privileged Documents, Writings, and Communications that support paragraph 71 of Your FIRST CROSS CLAIM.
REQUEST NO. 22:
Produce all Documents, Communications, and Writings Relating To any and all responses contained in Your responses to Defendant Jed Margolin's First Set of Interrogatories to Patrick Canet.
REQUEST NO. 23:
Produce all Documents, Communications, and Writings identifying the debtors and amounts owed in the FRENCH ACTION that is the basis of Your Chapter 15
Petition.
REQUEST NO. 24:
Produce all Documents, Communications, and Writings supporting Your assertion that Bank Melli's claim against ZANDIAN in the FRENCH ACTION that is the basis of Your Chapter 15 Petition has been approved.
REQUEST NO. 25:
Produce all Documents, Communications, and Writings Relating To ZANDIAN's (or Computer World's) debt to Bank Melli including the purpose for incurring the debt.
REQUEST NO. 26:
Produce all Documents, Communications, and Writings Relating To the amount of money that You have already received from ZANDIAN in the FRENCH ACTION or otherwise.
REQUEST NO. 27:
Produce all Documents, Communications, and Writings Related To Your attempt(s) to
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collect Your Judgment against ZANDIAN in the FRENCH ACTION.
REQUEST NO. 28:
Produce all Documents, Communications, and Writings Related To Your attempt(s) to collect Your Judgment in the FRENCH ACTION against ZANDIAN in Switzerland.
REQUEST NO. 29:
Produce all Documents, Communications, and Writings Related To Your attempt(s) to collect Your Judgment against ZANDIAN in the FRENCH ACTION in Nevada.
REQUEST NO. 30:
Produce all Documents, Communications, and Writings Related To Your attempt(s) to collect Your Judgment against ZANDIAN in the FRENCH ACTION anywhere else in the United States.
REQUEST NO. 31:
Produce all Documents, Communications, and Writings Related To Your attempt(s) to collect Your Judgment against ZANDIAN in the FRENCH ACTION in any other country.
REQUEST NO. 32:
Produce all Documents, Communications, and Writings Related To any and all agreements You have with ZANDIAN (whether written or oral) Relating To Your Chapter 15 Petition and/or this adversary proceeding.
REQUEST NO. 33:
Produce all agreements You have with SADRI Relating To Your Chapter 15 Petition and/or this adversary proceeding.
REQUEST NO. 34:
Produce all agreements You have with RAY KOROGHLI Relating To Your Chapter 15 Petition and/or this adversary proceeding.
REQUEST NO. 35:
Produce all agreements You have with SATHSOWI T. KOROGHLI Relating To Your Chapter 15 Petition and/or this adversary proceeding.
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REQUEST NO. 36:
Produce all agreements You have with KMT Relating To Your Chapter 15 Petition and/or this adversary proceeding.
DATED: This 19th day of January, 2018.
BROWNSTEIN HYATT FARBER SCHRECK, LLP
__________________
Matthew D. Francis
Arthur A. Zorio
5371 Kietzke Lane
Reno, NV 89511
Telephone: 775-324-4100
Attorneys for JED MARGOLIN
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CERTIFICATE OF SERVICE
Pursuant to Fed. R. Civ. P. 5(b), I certify that I am an employee of BROWNSTEIN HYATT FARBER SCHRECK, LLP, and on this 19th day of January, 2018, I served the document entitled DEFENDANT JED MARGOLIN'S FIRST SET OF REQUESTS FOR PRODUCTION TO PATRICK CANET on the parties listed below via the following:
[X] VIA FIRST CLASS U.S. MAIL: by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the United States mail at Reno, Nevada, addressed as follows:
Dana Jonathon Nitz, Esq.
Yanxiong Li, Esq.
Wright, Finlay & Zak, LLP
7785 W. Sahara Avenue., Suite 200 Las Vegas, NV 89117
yli@wrightlegal.net
Jeffrey L. Harman, Esq.
HARMAN & HARTMAN 510 West Plumb Lane, Suite B Reno, NV 89509
notices@bankruptcyreno.corn
[ ] BY PERSONAL SERVICE: by personally hand-delivering or causing to be hand delivered by such designated individual whose particular duties include delivery of such on behalf of the firm, addressed to the individual(s) listed, signed by such individual or his/her representative accepting on his/her behalf. A receipt of copy signed and dated by such an individual confirming delivery of the document will be maintained with the document and is attached.
[ ] VIA COURIER: by delivering a copy of the document to a courier service for over-night delivery to the foregoing parties.
[ ] VIA ELECTRONIC SERVICE: by electronically filing the document with the Clerk of the Court using the ECF system which served the following parties electronically:
[Nancy Lindsley]
Employee Brownstein Hyatt Farber Schreck
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