Free Praecipe - District Court of Delaware - Delaware

Case 1 :07-cv-00273-JJF Document 30 Filed 12/10/2007 Page 1 of 3
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EN TE UNTTED STATES DISTRICT COURT __
FUR THE DISTRICT OF DELAWARE
Case No. @7——CV- 00273-*** E
Pamela Carvel, as Citizen, ) A@NDED gi *‘
as Delaware Ancillary Administrator ) CGMPLAHT T
for Agnes Carvel Estate, ) ;_
as Member for Thomas and Agnes Carvel Foundation ) F `
Plaintiffs ) M
v. ) DEMAND FGR
William Griffin ) JIJRY TRIAL
" Marie Abplanalp )
Salvatore Molella )
.. Robert Davis )
and )
John/Jane Doe 1-20 )
Doe Corp. 1-20 )
Defendants )
_,___..._,._.__._.__.__,___,.__.__)
PRAECHE
PLEASE ISSUE a subpoena duces recom to the Sheriff of New Castle County,
directing him to serve said subpoena duces recom along with a copy of the attached _
Document Demand upon the Defendants at the address listed below:
W. Donald Sparks, H
Richards, Layton & Finger, P.A.
One Rodney Square, P.O. Box 551
Wilmington, DE 19801
1, 302-651-7700
U compelling production of the following documents by Defendants within 20 days to;
Pamela Caryel
2 8 Old Brompton Road, Suite 158
London SW7 3SS England UK.
US tel/fax 1 954 524 1909

Case 1:07-cv-00273-JJF Document 30 Filed 12/10/2007 Page 2 of 3
DOCUMENTS DEMANDED;
The following documents may be produced in paper form or as scanned images on
Zipl00 disk or CD with ".pdt", “.tif", “.exe” or ".max" file extensions. lf the file format
is unreadable, production of the original paper document will be requested. A list should
be provided to all "original" documents that are missing and that only exist as a copy.
Defendants William Griffin, Marie Ablpanalp Holcombe, Salvador Molella, each having
answered as "Member and Director of the Thomas and Agnes Carvel Foundation", and
each being represented by alleged foundation attorneys, are each herewith requested,
along with their agents and employees, to provide the following that are within their
possession or control in any capacity:
‘ 1. All documents and correspondence regarding to the formation of the “Thomas
and Agnes Carvel Foundation", including but not limited to: the Certificate of
_ Incorporation, the By-Laws, corporate filings, the stated purpose, the first meeting,
elections, etc.
2. All documents, correspondence, resolutions, and minutes of any kind reflecting or
memorializing alleged foundation meetings or elections, whether by shareholders,
members, directors, officers, committees, managers, employees, etc.
3. All documents and correspondence regarding the identity of alleged shareholders,
members, directors, officers, managers, employees, etc.; the qualifications by which each
acquired their status; disclosure of all payments to these persons where in money, favors,
or barter.
4. All documents and correspondence regarding Carvel Corp. stock, including but
not limited to: any due diligence, copies of stock certificates, stock powers, dates of
donations, identity of donors, other proof of donations, purpose of donations, stock
valuations, stock sale, proof of stock sale price received, identity of stock purchasers, etc.
5. All documents and correspondence regarding Carvel Corp. subsidiaries,
successors, mergers, their assets, and their value, including but not limited to:
, Franchise Stores Realty Corp.
CCCC Holding Corp.
All American Sports City
` Mdreas Distributors Inc.
Action 800 Inc.
Kingdom of Pam, Inc.
Chauncey Advertising Inc.
Andreas Holdings Corp.
6. All documents and correspondence regarding income and disbursements
including but not limited to: all account ledgers or the equivalent, bank statements with
cancelled checks; all financial statements or the equivalent, all resolutions approving

Case 1:07-cv-00273-JJF Document 30 Filed 12/10/2007 -7 Page 3 of 3
disbursement or acceptance of donations; any restrictions of purpose for income received;
proof of all payments in money, service, barter, or otherwise; attorney invoices, etc.
7. All documents and correspondence regarding foundation managernent, including
but not limited to: resolutions, agreements, contracts, stipulations, restrictions,
adjudications, and a list describing of all verbal arrangements of any kind.
8. All documents and correspondence regarding the U.S. Internal Revenue Service
or U.K. Inland Revenue, including but not limited to: application for tax-exempt status,
tax returns, sale of assets, disqualified persons, prohibited transactions, audits,
assessments, penalties, payments to accountants, accountants’ notes or reports, etc.
9. All documents and correspondence regarding the sale of real estate, including but
·‘ not limited to: appraisals as of 1990, appraisals as of date of sale, due diligence, proof of
public offering, proof of fair market value, identity of the purchasers, proof of payment,
., resolutions, agreements, arrangements, stipulations, mortgages, disclosure of the
relationship between named Defendants and purchasers, etc. for:
228 Orange Tree Dr., Atlantis FL A
265 N. Country Club Dr., Atlantis, FL
95 S. Central Park Avenue, Hartsdale, NY
100 Winding Road Farm, Ardsley, NY
10. All documents and correspondence regarding Hudson Valley Bank, including but
not limited to: leases at the Hudson Valley Bank Building; the identity of the landlord;
the Bank’s relationship to the landlord; the Bank’s relationships with named Defendants;
U.S. Treasury Securities or other investments; any accounts iirnded with Carvel money or
the sale proceeds of Carvel Corp. stock, etc.
11. All documents and correspondence regarding the New York Attorney General’s
criminal investigations of the conspiracies in the sale of Dutchess County properties,
including but not limited to: due diligence, William Zuga, Francis Zarro, resolutions,
participation in legal proceedings, recover of rnisappropriated funds, etc.
12. All documents, correspondence, resolutions regarding any legal proceedings in
., Delaware Chancery Court.
I 13. All documents, correspondence, resolutions, and proof of payments to Orrick
Herrington Sutcliffe LLP, Steven Fink, Richards, Layton & Finger, P.A., or any other
attorneys for defense of this Federal Complaint. /
..·‘‘
December 6, 2007 Pamela Carvel, appearing pro se
28 Old Brompton Road, Suite 158
London SW7 3SS England U.K.
US tel/fax 1 954 524 1909