Free Notice (Other) - District Court of Delaware - Delaware

Case 1:04-cv-01026-KAJ Document 56-3 Filed O4/25/2006 Paget of 4
EXHIBIT B
DOCUMENTS REQUESTED
l. Airy and all papers, writings or documents in your possession, custody or
control which relate to, support or contradict any of the facts alleged in the Complaint or
any allegation in the Complaint.
2. Any and all papers, writings or documents in your possession, custody or
control which relate to, support or contradict in any way any of the Defendant’s
affirmative defenses alleged in the Answer or asserted by the Defendant.
3. Any and all documents of any kind which relate to, support or contradict
any party’s position or any of the issues that are the subject matter of this litigation.
4. Any and all documents or correspondence setting forth the terms of
retention of the Defendant’s services by the Debtors or the tenns of the parties’ business
dealings, including contracts, agreements, or letters confirming a party’s understanding.
5. Any and all papers, writings or documents in your possession, custody or
control, which relate in any way to the Payments.
6. Any and all correspondence, including internal or electronic
correspondence, concerning any and all matters alleged in the Complaint and in the
Answer to the Complaint.
7. Any and all correspondence between the Defendant and the Debtors
during the Preference Period.
8. Any and all correspondence between the Defendant and the Debtors
during the two—year period immediately preceding the Preference Period.
9. Any and all correspondence, including internal or electronic
correspondence, which relate in any way to the course of business and/or financial affairs
°2m"` 6

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between the Debtors and the Defendant during the Preference Period.
10. Any and all correspondence, including internal or electronic
correspondence, which relate in any way to the course of business and/or financial affairs
between the Debtors and the Defendant during the two—year period preceding the
Preference Period.
ll. Any and all written statements that you have obtained from any person in
connection with this lawsuit.
12. Any and all written communications that the Defendant, or anyone
representing the Defendant, had at any time with the Debtors or any representative of the
Debtors concerning the subject matter of this litigation.
13. Any and all written communications that the Defendant, or anyone
representing the Defendant, had with any employee or fonner employee of the Debtors
concerning the subject matter of this litigation.
14. Any and all papers, writings, or documents in your possession, custody or
control which relate to any work performed or services provided by the Defendant to or
for the Debtors during the Preference Period.
15. Any and all papers, writings, or documents in your possession, custody or
control which relate to any work performed or services provided by the Defendant to or
for the Debtors during the two-year period immediately preceding the Preference Period.
16. Any and all invoices, billing statements or other documents describing
goods and/or services provided by the Defendant to the Debtors during the Preference
Period.
17. Any and all invoices, billing statements or other documents describing
goods and/or services provided by the Defendant to the Debtors during the two—year

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period immediately preceding the Preference Period.
18. Any and all Accounts Receivables aging reports and accounting records
relating to, referring to or regarding the Debtors during the Preference Period.
19. Any and all Accounts Receivables aging reports and accounting records
relating to, referring to or regarding the Debtors during the two—year period preceding the
Preference Period.
20. All documents referring to, relating to, indicating or constituting payments
made by the Debtors to the Defendant for goods and/or services during the Preference
Period.
21. All documents referring to, relating to, indicating or constituting payments
made by the Debtors to the Defendant for goods and/or services during the two—year
period immediately preceding the Preference Period.
22. All papers, writings or documents in your possession, custody or control
which relate in any way to the course of business and/or financial affairs between the
Debtors and the Defendant during the Preference Period.
23. All papers, writings or documents in your possession, custody or control
which relate in any way to the course of business and/or financial affairs between the
Debtors and the Defendant during the two—year period preceding the Preference Period.
24. Any and all papers, writings or documents in the your possession, custody
or control which relate to, support or contradict the Defendant’s contention that the
Payments were in payment of a debt incurred by the Debtors in the ordinary course for
business, made in the ordinary course of business and made according to the ordinary
business terms between the parties under 11 U .S.C. § 547(c)(2).
25. Any and all papers, writings or documents in the your possession, custody

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or control which relate to, support or contradict the Defendant’s contention that the
Defendant provided new value to the Debtors under ll U .S.C. § 547(c)(l).
26. Any and all papers, writings or documents in the your possession, custody
or control which relate to, support or contradict the Defendant’s contention that the
Defendant provided new value to the Debtors under ll U .S.C. § 547(c)(4).
27. Any and all papers, writings or documents in the your possession, custody
or control which relate to, support or contradict the Defendant’s contention that it was a
secured creditor when the Debtors made the Payments to the Defendant.
28. Any and all papers, writings or documents in the your possession, custody
or control which relate to, support or contradict the Defendant’s’ contention that the
Debtors granted the Defendant a security interest in equipment sold by the Defendant to
the Debtors.
29. Any and all papers, writings or documents in the your possession, custody
or control referring to, relating to, or indicating that the Defendant has or had at the time
of the Payments a perfected security interest in the equipment sold by the Defendant to
the Debtors.
30. Any and all papers, writings or documents in the your possession, custody
or control which relate to, support or contradict the Defendant’s contention that the
Payments are barred by the doctrine of set off and/or recoupment
31. All documents which you referred to, consulted, or relied upon when you
prepared and responded to the Creditor Trust Trustee’s First Set of Interrogatories
Directed to Defendant.