Free Motion to Compel - District Court of Connecticut - Connecticut

Case 3:01-cv-02158-WWE

Document 68-2

Filed 11/01/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DONALD WAINRIGHT, JANET WAINRIGHT, AND DEBORAH A. RUSSO-WILLIAMS, -x DOC.// 301-CV-2158 (WWE)

-AGAINST-

PLAINTIFFS,

OSM COMMUNICATIONS, INC., ISRAEL H. POLANSKY, ROBERT E. POLANSKY, AND ANNE POLANSKY,
DEFENDANTS.
MARCH 29,2004

NOTICE OF DEPOSITION OF ROBERT E. POLANSKY PLEASE TAKE NOTICE, that pursuant to Rules 30(b)(5), 30(b)(2) and 45 of the Federal Rules of Civil Procedure, the Plaintiffs in the above-captioned case, by the undersigned attorney will take the deposition of the party defendant before a Certified Court Reporter or some other competent authority, by videotape, in the above captioned matter, as follows: NAME: ROBERT E. POLANSKY DATE: FRIDAY April 23, 2004 TIME: 10:00 A.M. LOCATION: 412 Orange Street New Haven, Connecticut 06511, at the Law Offices of Robert E. Arnold LLC. The deponent is required to appear with the documents identified in Schedule A attached hereto. The deposition is being taken for the purpose of discovery and / or use at trial or both, or for such other purposes as are permitted under the applicable and governing rules, pursuant to Federal Rules of Civil Procedure, and will continue from day to day until completed. T I Rober£fe"Arnofd, Attorney of Record for Plaintiffs Law Offices of Robert E. Arnold LLC 412 Orange Street New Haven, CT 06511 (203) 777-3000 tel. (203) 777-2900 fax Federal Bar //CT 18093

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Schedule A For the purposes of this request, the term "documents" or "document" shall mean all writings of any type or kind, including but not exclusively by example and without limitation the following, in both original and copy and non-identical copy form: correspondence, memoranda, notes, diaries, statistics, letters, telegrams, emails, minutes, contracts, reports, studies, checks (front and back), statements, ledgers, promissory notes, receipts, returns, summaries, pamphlets, bulletins, printed matter, books, prospectuses, certificates, drawings, doings, doodles, plans, interoffice and intraoffice communications both paper and electronic, offers, faxes, notations made for the purpose of facilitating any of the communications alluded to herein, including communications made in the form of conversations during meetings, on the telephone, by interoffice and intraoffice intercom. In addition, as used herein, "documents" shall mean newspapers, magazines, and publications of any type or form, and any clippings or excerpts therefrom, press releases, computer printouts, teletypes, telecopies, invoices, ledgers, worksheets, spreadsheets, (including all drafts, modifications, alterations, amendments and/or changes of the foregoing) any and all graphic or aural representations of any kind, and/or transcriptions thereof. 1. Documents concerning any interest in OSM Communications, Inc. (hereinafter "OSM") on the part of Israel Polansky, including but not limited to methods, terms and payments or repayments of any funds. 2. Documents concerning any interest in OSM Communications, Inc. (hereinafter "OSM") on the part of Robert Polansky, including but not limited to methods, terms and payments or repayments of any funds. 3. Documents concerning any interest in OSM Communications, Inc. (hereinafter "OSM") on the part of Anne Polansky, including but not limited to methods, terms and payments or repayments of any funds. 4. Minute books of OSM, including but limited to minutes of meetings of OSM's Board of Directors and Shareholders. 5. Documents concerning Israel Polansky's sources of income from 1996 to the present. 6. Documents concerning Robert Polansky's sources of income from 1996 to the present. 7. Documents concerning Anne Polansky's sources of income from 1996 to the present. 8. Documents concerning all financial statements, audited and unaudited, of OSM from 1997 to the present. 9. Documents concerning all attempts by OSM to obtain investment funds from 1996 to the present. 10. Documents concerning employment contracts and the personnel files with OSM for Israel Polansky, Robert Polansky, Anne Polansky, Donald Wainright and Deborah Williams-Russo. 11. Documents concerning any payments made from OSM to Donald Wainright, OSM to Robert Polansky, OSM to Anne Polansky, Robert Polansky to Donald Wainright, Israel Polansky to Donald Wainright, Israel Polansky to Robert Polansky, Israel Polansky to Anne Polansky and Israel Polansky to OSM, to include but not limited to copies of all checks front and back.

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12. Documents concerning any payments made from OSM to Deborah Russo-Williams, Israel Polansky to Deborah Russo-Williams, Robert Polansky to Deborah RussoWilliams, to include but not limited to copies of all checks front and back. 13. Documents concerning any payment to Robert Polansky and Anne Polansky from any trust controlled by Israel Polansky. 14. Documents concerning any loans by any person, trust or business to OSM, Robert Polansky, Israel Polansky and Anne Polansky. 15. Documents concerning any public or private offering of OSM, including but not limited to documents concerning the personnel structure, financial viability, prospectus, and financial resources of OSM. 16. Documents concerning payments made by Israel Polansky for the debts of OSM. 17. Federal and state income tax returns for the years 1996 to the present for Israel Polansky, Robert Polansky, Anne Polansky and OSM. 18. Documents concerning any other suits or cases against OSM, Robert Polansky, Israel Polansky, Anne Polansky for failure to pay wages or debts. 19. Documents concerning the business entity Valassis. 20. Documents concerning the business entity VISM. 21. Documents concerning any line of credit issued to or loans to OSM. 22. Documents concerning any business relationship between OSM and Ameristar Capital Corporation. 23. Documents concerning any payments made by OSM to or from Ameristar Capital Corporation.

24. Documents concerning any meelings with any potential investors in OSM.
25. Documents concerning any interest in real property by OSM, Robert Polansky and Anne Polansky, either acquired, transferred or sold for the years 1996 to the present. 26. All documents between you and any other party relating to any matter asserted in the complaint and your cross complaint. 27. Copies of Checks, front and back, check registers and bank statements of any accounts used to pay any expenses, payroll or costs of any kind of OSM Communications, Inc. and any of its affiliates from 1996 to the present, including any payments claimed as investments. 28. A list of all checking, savings, or any other account, including investment accounts, with the account numbers, of which Robert Polansky or any other officer or representative was a signatory on behalf of OSM, including the name and address of the banks or issuers of the accounts, since 1996. 29. The federal and state income tax returns for the years 1996 to the present for OSM, Robert Polansky, Anne Polansky and Israel Polansky.

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CERTIFICATION

THIS IS TO CERTIFY THAT ACOPYOFTHEFOREGOING WASTRANSMITTEDVIAFACSIMILE
AND MAILED, POSTAGE PREPAID, THIS____ DAY OF MARCH, 2004, TO:

COUNSELFORTHEDEFENDANTS OSM COMMUNICATIONS, INC., ANDROBERTE. POLANSKY. RICHARD C. FGLDMAN, ESQ. KEITH R. AINSWORTH, ESQ. EVANS, FELDMAN & BOYER, LLC 261 BRADLEY STREET

P.O. BOX 1694
NEW HAVEN, CONNECTICUT 06507-1694

TEL. 203-772-4900
FAX. 203-782-1356

COUNSEL FOR THE DEFENDANTS ISRAEL H. POLANSKY AND ANNE POLANSKY

J. MICHAEL SULZBACH 385 ORANGE STREET
NEW HAVEN, CT 06511
TEL. 203-781-0880 FAX. 203-781-0861

BY: ROBERT E. ARNOLD, ESQ. (CT FEDERAL BAR # CT18093)

Original to: United States District Court, District of Connecticut 915 LAFAYETTE BOULEVARD BRIDGEPORT, CONNECTICUT 06604 Phone: (203) 579-5861 Attn: Clerk's Office
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CERTIFICATION

THIS IS TO CERTIFY THAI' A COPY OF THE EOBEGO1NG WAS TRANSMITTED VIA FACSIMILE AND MAILED, POSTAGE PREPAID, THIgx^j_ DAY OF MARCH, 2004, TO:

COUNSELFORTHEDEFENDANTS OSM COMMUNICATIONS, INC., AND ROBERT E. POLANSKY.

RICHARD C. FELDMAN, ESQ. KEITH R. AINSWORTH, ESQ. EVANS, FELDMAN & BOYER, LLC 261 BRADLEY STREET

·

P.O. Box 1694
NEW HAVEN, CONNECTICUT 06507-1694
TEL. 203-772-4900

FAX. 203-782-1356
COUNSEL FOR THEDEFENDANTS ISRAEL H. POLANSKY AND ANNE POLANSKY J. MICHAELSULZBACH 385 ORANGE STREET NEW HAVEN, CT 06511
TEL. 203-78)-0880 FAX. 203-781-0861

BY:

ROBERT E. ARNOLD, ESQ. (CT FEDERAL BAR #CT18093)

Original to: United States District Court, District of Connecticut 915 LAFAYETTE BOULEVARD BRIDGEPORT, CONNECTICUT 06604 Phone: (203) 579-5861 Attn: Clerk's Office
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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DONALD WAINRIGHT, JANET WAINRIGHT, AND DEBORAH A. RUSSO-WILLIAMS,
PLAINTIFFS,
-AGAINST-

DOC.# 301-CV-2158 (WWE)

OSM COMMUNICATIONS, INC., ISRAEL H. POLANSKY, ROBERT E. POLANSKY, AND ANNE POLANSKY,
DEFENDANTS. MARCH 19,2004

RE-NOTICE OF DEPOSITION OF ANNE POLANSKY PLEASE TAKE NOTICE, that pursuant to Rules 30(b)(5), 30(b)(2) and 45 of the Federal Rules of Civil Procedure, the Plaintiffs in the above-captioned case, by the undersigned attorney will take the deposition of the party defendant before a Certified Court Reporter or some other competent authority, by videotape, in the above captioned matter, as follows: NAME: ANNE POLANSKY DATE: WEDNESDAY MAY 26,2004 TIME: 09:15 A.M. LOCATION: 412 Orange Street New Haven, Connecticut 06511, at the Law Offices of Robert E. Arnold LLC. The deponent Js required to appear with the documents identified in Schedule A attached hereto. The deposition is being taken for the purpose of discovery and / or use at trial or both, or for such other purposes as are permitted under the applicable and governing rules, pursuant to Federal Rules of Civil Procedure, and will continue from day to day until completed. THE, Robeff E. Arr^^ttorneyofRecord lor Plaintiffs Law OfRCeTof Robert E. Arnold LLC 412 Orange Street New Haven, CT 06511 (203) 777-3000 tel. (203) 777-2900 fax Federal Bar # CT 18093

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CERTIFICATION

THIS IS TO CERTIFY THAT A COPY OF THE FOREGOING WAS MAILED, POSTAGE PREPAID,
THIS____ DAY OF MAY, 2004, TO:

COUNSELFORTHEDEFENDANTSOSM COMMUNICATIONS, INC., AND ROBERTE. POLANSKY. RICHARDC. FELDMAN, Esq. KEITH R, AINSWORTH, ESQ. EVANS, FELDMAN & BOYER, LLC 261 BRADLEY STREET

P.O. Box 1694
NEW HAVEN, CONNECTICUT 06507-1694

TEL. 203-772-4900 FAX. 203-782-1356
COUNSEL FOR THEDEFENDANTS ISRAEL H. POLANSKY AND ANNE POLANSKY

J. MICHAEL SULZBACH

385 ORANGE STREET
NEW HA YEN, CT 06511 TEL. 203-781-0880

FAX. 203-781-0861

BY:

ROBERT E. ARNOLD, ESQ. (CT FEDERAL BAR # CTI8093)

Original to: United States District Court, District of Connecticut 915 LAFAYETTE BOULEVARD BRIDGEPORT, CONNECTICUT 06604 Phone: (203) 579-5861 Attn: Clerk's Office

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Schedule A For the purposes of this request, the term "documents" or "document" shall mean all writings of any type or kind, including but not exclusively by example and without limitation the following, in both original and copy and non-identical copy form: correspondence, memoranda, notes, diaries, statistics, letters, telegrams, emails, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, bulletins, printed matter, books, prospectuses, certificates, drawings, doings, doodles, plans, interoffice and intraofflce communications both paper and electronic, offers, faxes, notations made for the purpose of facilitating any of the communications alluded to herein, including communications made in the form of conversations during meetings, on the telephone, by interoffice and intraofflce intercom. In addition, as used herein, "documents" shall mean newspapers, magazines, and publications of any type or form, and any clippings or excerpts therefrom, press releases, computer printouts, teletypes, telecopies, invoices, ledgers, worksheets, spreadsheets, (including all drafts, modifications, alterations, amendments and/or changes of the foregoing) any and all graphic or aural representations of any kind, and/or transcriptions thereof. 1. All documents between you and any other party relating to any matter asserted in the complaint and your cross complaint. 2. Documents, copies of Checks, front and back, and check registers of any accounts used to pay any_cxpenses, payroll or costs of any kind of OSM Communications, Inc. and any of its affiliates from 1996 to the present, including any payments claimed as investments. 3. A list of ail checking, savings, or any other account, including investment accounts, with the account numbers, of which you were or are a signatory, including the name and address of the banks or issuers of the accounts, since 1996. 4. Your federal and state income tax returns for the years 1996 to the present. 5. All documents relating to any interest in real property you either acquired, transferred or sold for the years 1996 to the present.

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DONALD WAINRIGHT, JANET WAINRTGHT, AND DEBORAH A. RUS SO- WILLIAMS,
PLAINTIFFS,
-AGAiNST-

DocJ 301-CV-2158 (WWE)

OSM COMMUNICATIONS, INC., ISRAEL H. POLANSKY, ROBERT E. POLANSKY, AND ANNE POLANSKY,
DEFENDANTS. MARCH 19, 2004

NOTICE OF DEPOSITION OF ROBERT E. FOLANSKY PLEASE TAKE NOTICE, that pursuant to Rules 30(b)(5), 30(b)(2) and 45 of the Federal Rules of Civil Procedure, the Plaintiffs in the above-captioned case, by the undersigned attorney will take the deposition of the party defendant before a Certified Court Reporter or some other competent authority, by videotape, in the above captioned matter, as follows; NAME: ROBERT E. POLANSKY DATE: WEDNESDAY MAY 26, 2004 TIME: 11:00 A.M. LOCATION: 412 Orange Street
New Haven, Connecticut 06511,

at the Law Offices of Robert E. Arnold LLC. The deponent is required to appear with the documents identified in Schedule A attached hereto. The deposition is being taken for the purpose of discovery and / or use at trial or both, or for such other purposes as are permitted under the applicable and governing rules, pursuant to Federal Rules of Civil Procedure, and will continue from day to day until completed.

By._
Robert E.^rjioid^Attorney of Record for Robert E. Arnold LLC Plaintiffs Law Offices of

412 Orange Street
New Haven, CT 06511 (203) 777-3000 tel. (203) 777-2900 fax Federal Bar # CT 18093

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CERTIFICATION

THIS IS TO CERTIFY THAT A COPY OF THE FOREGOING WAS MAILED, POSTAGE PREPAID,
THIS____ DAY OF MAY, 2004, TO:

COUNSELFORTHEDEFENDANTSOSM COMMUNICATIONS, INC., AND ROBERTE. POLANSKY.
RICHARD C. FELDMAN, ESQ. KEITH R. AINSWORTH, ESQ. EVANS, FELDMAN & BOYER, LLC 261 BRADLEY STREET

P.O. Box 1694
NEW HAVEN, CONNECTICUT 06507-1694 TEL. 203-772-4900 FAX. 203-782-1356 COUNSEL FOR THEDEFENDANTS ISRAEL H. POLANSKY AND ANNE POLANSKY J. MICHAELSULZBACH 385 ORANGF, STREET
NEW HAVEN, CT 06511 TEL. 203-781-0880

FAX. 203-781-0861

BY:

ROBERT E. ARNOLD, ESQ. (CT FEDERAL BAR # CT18093)

Original to: United States District Court, District of Connecticut 915 LAFAYETTE BOULEVARD BRIDGEPORT, CONNECTICUT 06604 Phone:(203)579-5861 Attn: Clerk's Office

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Schedule A For the purposes of this request, the term "documents" or "document" shall mean all writings of any type or kind, including but not exclusively by example and without limitation the following, in both original and copy and non-identical copy form: correspondence, memoranda, notes, diaries, statistics, letters, telegrams, emails, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, bulletins, printed matter, books, prospectuses, certificates, drawings, doings, doodles, plans, interoffice and intraoffice communications both paper and electronic, offers, faxes, notations made for the purpose of facilitating any of the communications alluded to herein, including communications made in the form of conversations during meetings, on the telephone, by interoffice and intraoffice intercom. In addition, as used herein, "documents" shall mean newspapers, magazines, and publications of any type or form, and any clippings or excerpts therefrom, press releases, computer printouts, teletypes, telecopies, invoices, ledgers, worksheets, spreadsheets, (including all drafts, modifications, alterations, amendments and/or changes of the foregoing) any and all graphic or aural representations of any kind, and/or transcriptions thereof. 1. All documents between you and any other party relating to any matter asserted in the complaint and your cross complaint. 2. Documents, copies of Checks, front and back, bank statements, and check registers of any accounts used to pay any^expenses, payroll or costs of any kind of OSM Communications, Inc. and any of its affiliates from 1996 to the present, including any payments claimed as investments. 3. A list of all checking, savings, or any other account, including investment accounts, with the account numbers, of which you were or are a signatory, including the name and address of the banks or issuers of the accounts, since 1996. 4. Your federal and state income tax returns for the years 1996 to the present. 5. All documents relating to any interest in real property that you either acquired, transferred or sold for the years 1996 to the present.

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DONALD WAINRIGHT, JANET WAINRIGHT, AND DEBORAH A. RUSSO-WILLIAMS,
PLAINTIFFS, AGAINST-

Doc.# 301-CV-2158 (WWE)

OSM COMMUNICATIONS, INC., ISRAEL H. POLANSKY, ROBERT E. POLANSKY, AND ANNE POLANSKY,
DEFENDANTS. MARCH 2, 2004

RE-NOTICE OF DEPOSITION OF ANNE POLANSKY PLEASE TAKE NOTICE, that pursuant to Rules 30(b)(5), 30(b)(2) and 45 of the Federal Rules of Civil Procedure, the Plaintiffs in the above-captioned case, by the undersigned attorney will take the deposition of the party defendant before a Certified Court Reporter or some other competent authority, by videotape, in the above captioned matter, as follows: NAME: ANNE POLANSKY DATE: FRIDAY MARCH 19,2004 TIME: 01:00 P.M. LOCATION: 412 Orange Street New Haven, Connecticut 06511, at the Law Offices of Robert E. Arnold LLC. The deponent is required to appear with the documents identified in Schedule A attached hereto. The deposition is being taken for the purpose of discovery and / or use at trial or both, or for such other purposes as are permitted under the applicable and governing rules, pursuant to Federal Rules of Civil Procedure, and will continue from day to day until completed.

RoberfE. A'rnold, Attorney of Record for Plaintiffs Law Offices of Robert E. Arnold LLC
412 Orange Street

New Haven, CT 06511 (203) 777-3000 tel. (203) 777-2900 fax Federal Bar # CT 18093

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Schedule A For the purposes of this request, the term "documents" or "document" shall mean all writings of any type or kind, including but not exclusively by example and without limitation the following, in both original and copy and non-identical copy form: correspondence, memoranda, notes, diaries, statistics, letters, telegrams, emails, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, bulletins, printed matter, books, prospectuses, certificates, drawings, doings, doodles, plans, interoffice and intraoffice communications both paper and electronic, offers, faxes, notations made for the purpose of facilitating any of the communications alluded to herein, including communications made in the form of conversations during meetings, on the telephone, by interoffice and intraoffice intercom. In addition, as used herein, "documents" shall mean newspapers, magazines, and publications of any type or form, and any clippings or excerpts therefrom, press releases, computer printouts, teletypes, telecopies, invoices, ledgers, worksheets, spreadsheets, (including all drafts, modifications, alterations, amendments and/or changes of the foregoing) any and all graphic or aural representations of any kind, and/or transcriptions thereof. 1. All documents between you and any other party relating to any matter asserted in the complaint and your cross complaint. 2. Copies of Checks, front and back, and check registers of any accounts used to pay any expenses, payroll or costs of any kind of OSM Communications, Inc. and any of its affiliates from 1996 to the present, including any payments claimed as investments. 3. A list of all checking, savings, or any other account, including investment accounts, with the account numbers, of which you were or are a signatory, including the name and address of the banks or issuers of the accounts, since 1996. 4. Your federal and state income tax returns for the years 1996 to the present. 5. All documents relating to any interest in real property you either acquired, transferred or sold for the years 1996 to the present.

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT
_ _ _ _ _ _ _ _ _ _ _ _ ______________________.,,,,.-----_____ _ _ _ _ ,, . . ____v, ,, _ _ ,, , - ----________ ~ _ - ~ _________________ -- -- --V

DONALD WAINRIGHT, JANET WAINRIGHT, AND DEBORAH A. RUSSO-WILLIAMS,
PLAINTIFFS, AGAINST-

DocJ 301-CV-2158 (WWE)

OSM COMMUNICATIONS, INC., ISRAEL H. POLANSKY, ROBERT E. POLANSKY, AND ANNE POLANSKY,
DEFENDANTS.
_,,,___,,_______,,_____. _ _ _ _ __,,____ _ _ _ ^ , _ _, _ _ _ _ _ ~ _ _____ ^ _ _ _ _______v

MARCH 26,2004

RE-NOTICE OF DEPOSITION OF ISREAL H. POLANSKY PLEASE TAKE NOTICE, that pursuant to Rules 30(b)(5), 30(b)(2) and 45 of the Federal Rules of Civil Procedure, the Plaintiffs in the above-captioned case, by the undersigned attorney will take the deposition of the party defendant before a Certified Court Reporter or some other competent authority, by videotape, in the above captioned matter, as follows:

NAME:
DATE: TIME: LOCATION:

ISRAEL H. POLANSKY
Monday, March 29,2004 12:00 NOON Offices of J. Michael Sulzbach 385 Orange Street, New Haven, Connecticut 06511,

at the Law Offices of Robert E. Arnold LLC. The deponent is required to appear with the documents identified in Schedule A attached hereto. The deposition is being taken for the puipose of discovery and / or use at trial or both, or for such other purposes as are permitted under the applicable and governing rules, pursuant to Federal Rules of Civil Procedure, and will continue from day to day until completed.
tl-ETr Lrt.liN i Ijjr Ttm-BT--A-TXTTTT7T7C! o _ ^f^ ^^y j ,^-**"'LJ1--·v

Robert ^An^ldTAttorney ofRecord for Plaintiffs Law Offices of Robert E. Arnold LLC 412 Orange Street
New Haven, CT 06511

(203) 777-3000 tel. (203) 777-2900 fax
Federal Bar # CT 18093

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CERTIFICATION

THIS IS TO CERTIFY THAT A COPY OF THE FOREGOING WAS MAILED, POSTAGE PREPAID, THIS_ 7/7 DAY OF MARCH, 2004, TO:
~~&----*~~

COUNSELFORTHEDEFENDANTS OSM COMMUNICATIONS, INC., ANDROBERTE. POLANSKY.
RICHARD C. FELDMAN, ESQ. KESTH R. AINS WORTH, ESQ. EVANS, FELDMAN & BOYER, LLC 261 BRADLEY STREET

P.O. Box 1694
NEW HAVEN, CONNECTICUT 06507-1694

COUNSEL FOR THE DEFENDANTS ISRAEL H. POLANSKY AND ANNE POLANSKY J. MICHAEL SULZBACH 385 ORANGE STREET NEW HAVEN, CT 06511 TEL. 203-781-0880
FAX. 203-781-0861

BY:__ ROBERT E?ARNOLD, ESQ. (CT FEDERAL BAR #CT18093)

Original to: United States District Court, District of Connecticut 915 LAFAYETTE BOULEVARD BRIDGEPORT, CONNECTICUT 06604 Phone: (203) 579-5861 Attn: Clerk's Office

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Schedule A

For the purposes of this request, the term "documents" or "document" shall mean all writings of any type or kind, including but not exclusively by example and without limitation the following, in both original and copy and non-identical copy form: correspondence, memoranda, notes, diaries, statistics, letters, telegrams, emails, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, bulletins, printed matter, books, prospectuses, certificates, drawings, doings, doodles, plans, interoffice and intraoffice communications both paper and electronic, offers, faxes, notations made for the purpose of facilitating any of the communications alluded to herein, including communications made in the form of conversations during meetings, on the telephone, by interoffice and intraoffice intercom. In addition, as used herein, "documents" shall mean newspapers, magazines, and publications of any type or form, and any clippings or excerpts therefiom, press releases, computer printouts, teletypes, telecopies, invoices, ledgers, worksheets, spreadsheets, (including all drafts, modifications, alterations, amendments and/or changes of the foregoing) any and all graphic or aural representations of any kind, and/or transcriptions thereof. 1. All documents between you and any other party relating to any matter asserted in the complaint and your cross complaint. 2. Copies of Checks, front and back, and check registers of any accounts used to pay any expenses, payroll or costs of any kind of OSM Communications, Inc. and any of its affiliates from 1996 to the present, including any payments claimed as investments. 3. A list of all checking, savings, or any other account, including investment accounts, with the account numbers, of which you were or are a signatory, including the name and address of the banks or issuers of the accounts, since 1996. 4. Your federal and state income tax returns for the years 1996 to the present. 5. All documents relating to any interest in real property you either acquired, transferred or sold for the years 1996 to the present.

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