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Case1:O4-cv-01026-KAJ D0cument61-2 Filed O4/26/2006 Page10f3 1
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Schedule of Matters on Which Examination is Reguested
The deposition will include examination on:
l. All facts, allegations, areas and subject matter related to or identified in the Amended
Adversary Complaint to Avoid and Recover Preferential Transfers Pursuant to 11 U.S.C.
§§ 547 and 550 (the "Complaint").
2. All facts and circumstances that the Plaintiff maintains contradict the affirmative
defenses asserted in the answer to the Complaint (the "Answer") filed by Defendant. 4
3. All facts and circumstances that relate to, support, contradict or substantiate the claims
and defenses asserted in the Complaint and the Answer to the Complaint.
4. All contracts and agreements, whether written or oral, between the Debtors and the
Defendants.
5. The business relationship between the Debtors and the Defendants prior to and on the
date that the Debtors filed their bankruptcy petitions.
6. The transactions, course of business and/or financial affairs between the Debtors and
Defendants prior to and on the date that the Debtors filed their bankruptcy petitions,
including the manner and terms of the business transactions.
7. The ordinary course of business or financial affairs between the Debtors and the
Defendant.
8. The ordinary course of business or financial affairs in the Debtors’ industry and the
Defendants’ industry.
9. The Debtor's business transactions with the Defendants relating to goods or services
provided by the Defendants and received by the Debtors prior to and on the date that the
Debtors filed their bankruptcy petitions, including the manner in which the goods or
_ services were ordered, the manner in which the goods or services were provided, the
manner in which the goods or services were involved and the manner in which the goods
or services were paid.
l0. The Debtor's procedures, programs and systems for manually and! or electronically
receiving and processing business transactions with its vendors prior to and on the date
that the Debtors filed their bankruptcy petitions, including the information maintained by
the Debtors, the location and accessibility of the information and the manner in which it
is kept.
ll. The Debtor's procedures, programs and systems for manually and/or electronically
receiving and processing business transactions with the Defendants prior to and on the
date that the Debtors filed their bankruptcy petitions, including the information
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maintained by the Debtors, the location and accessibility of the information and the
manner in which it is kept.
12. Any responses, objections or documents produced in response to the requests for
production of documents (the "Document Requests") served on the Plaintiff by the
Defendants, including the circumstances relating to their maintenance or preparation of
such documents, and their context and meaning.
13. The Defendants’ efforts to locate documents responsive to the Document Requests.
14. Witnesses, including experts, whom the Defendants intends to call at trial in this
adversary proceeding.
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