1 XXXXXX

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4 Telephone: (209) 384-7887
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6 Attorney for TIFFANY XXXXXX
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8 SUPERIOR COURT OF CALIFORNIA COUNTY OF MERCED

9 In Re the Matter of Case No. 00000000

10 Petitioner: TIFFANY XXXXXX

DEMAND FOR PRODUCTION OF
11 and DOCUMENTS SET NO. ONE

12 Respondent: DAVID XXXXXX

13 PROPOUNDING PARTY: Petitioner/wife, TIFFANY XXXXXX

14 RESPONDING PARTY: Respondent/husband, DAVID XXXXXX
15 SET NO.: One (1)
16 TO: DAVID XXXXXX AND HIS ATTORNEY OF RECORD
17 DEMAND IS HEREBY MADE UPON YOU by Petitioner as follows:
18 That you serve on the undersigned, as an attorney for the demanding party, within 30
19 days of the date hereof, a written list and identifying description subscribed under oath, of each
20 document, paper, book, account, letter, photograph, object, or other tangible thing within your
21 possession, custody, or control relating to or falling within the following described categories
22 listed under the heading "DOCUMENTS TO BE PRODUCED."
23 In responding to this request, you must identify and furnish all documents in your
24 possession, custody, or control, regardless of where they are located, including any documents in
25 the possession of your attorney, banks, real estate agents, title company, union, employer, or
26 agent, or any other person who may be acting on your behalf.
27 A. Definition of "Document." As used in this request, the term "document" means all
28 originals or any nature whatsoever, and all non-identical copies of those originals, pertaining to

In re the Matter of Xxxxxx, Tiffany and David, Case No., 00000000

DEMAND FOR PRODUCTION OF DOCUMENTS SET NO. ONE (1)
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 1 any medium on which information is recorded, including but not limited to, punch cards, printout
2 sheets, movie film, slides, video tapes, audio tapes, compact discs, phonographic records,
3 photographs, microfilm, notes, letters, memoranda, ledgers, work sheets, books, magazines,
4 notebooks, diaries, calendars, appointment books, registers, charts, tables, papers, agreements,
5 contracts, purchase orders, acknowledgments, invoices, authorizations, budgets, analyses,
6 projections, transcripts, minutes of meetings of any kind, correspondence, telegrams, drafts,
7 computer discs or tapes, instructions, announcements, schedules, and price lists. In all instances,
8 if originals or non-identical copies of original documents are not available, "document" also
9 means identical copies of original documents and copies of non-identical copies.
10 B. Privilege. If any document is withheld under claim of privilege, please furnish a list
11 identifying each document for which the privilege is claimed, including the following
12 information for each such document:
13 1. The date, sender or author, recipient, type of document, number of pages, and
14 subject matter of the document;
15 2. The basis on which privilege is claimed; and
16 3. The paragraph or paragraphs of this request to which the document responds.
17 C. Documents No Longer in Your Possession, Custody, or Control. If any document
18 described in this request was, but no longer is, in your possession, or subject to your custody or
19 control, or is no longer in existence, please list each such document, including the following
20 information for each document:
21 1. The date, sender or author, recipient, type of document, number of pages, and
22 subject matter of the document;
23 2. Whether the document (a) is missing or lost; (b) has been destroyed; (c) has been
24 transferred, voluntarily or involuntarily, to another person or entity not subject to
25 your control; or (d) has otherwise been disposed of;
26 3. Explain the circumstances regarding the loss, destruction, or other disposition of
27 the document, and identify the person(s) who directed or authorized the
28 disposition and the date that it occurred; and

In re the Matter of Xxxxxx, Tiffany and David, Case No., 00000000

DEMAND FOR PRODUCTION OF DOCUMENTS SET NO. ONE (1)
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 1 4. If the document is still in existence, its present location and custodian.
2 D. Claim of Undue Burden. If you claim that production of any document or category of
3 documents described in this request would entail undue burden, please set forth separately in
4 your verified response to this request the following information with regard to each such
5 document or category of documents:
6 1. A brief description of the type(s) of documents, their location, and approximate
7 number of pages;
8 2. All reasons why you claim production of the documents would entail undue
9 burden; and
10 3. Any circumstances under which you could produce the documents without
11 undue burden (e.g., by submitting them at a later date than that specified at the
12 beginning of this request).
13 Respondent/wife further demands that you produce each and all of the things and
14 evidence so identified in the within paragraphs, organized and labeled to correspond with the
15 categories set forth under the heading DOCUMENTS TO BE PRODUCED, at the office of the
16 undersigned located at 1733 "O" Street, Merced, California, ON MAY 31, 2021, at the hour
17 of 10:00 a.m., and permit the inspection, copying, and photographs thereof at said time and
18 place.
19 The above-described documents, papers, books, accounts, letters, photographs, objects, or
20 other tangible things are currently in your possession, custody, or control; not privileged; and
21 relevant to the subject matter of this action or reasonably calculated to lead to discovery of
22 admissible evidence in this action.
23 This demand is made in accordance with the provisions of Code of Civil Procedure §§
24 2031.230 and 2031.280, subdivision (f), which provides, in part, that:
25 (1) A representation of inability to comply with the particular demand for
26 inspection shall affirm that a diligent search and a reasonable inquiry has been made
27 in an effort to comply with that demand. This statement shall also specify whether
28 the inability to comply is because the particular item or category has never existed,

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DEMAND FOR PRODUCTION OF DOCUMENTS SET NO. ONE (1)
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 1 has been destroyed, has been lost, misplaced, or stolen, or has never been or is no
2 longer, in the possession, custody, or control of the responding party. The statement
3 shall set forth the name and address of any natural person or organization known or
4 believed by that party to have possession, custody, or control of that item or category
5 of item.
6 (2) Any document demanded shall either be produced as they are kept in the usual
7 course of business, or be organized and labeled to correspond with the categories in
8 the demand. If necessary, the responding party at the reasonable expense of the
9 demanding party shall, through detection devices, translate any date compilations
10 included in the demand into reasonably usable form.
11 The word "writing" is used herein as it is defined in Evidence Code section 250, which
12 provides:
13 "Writing" means handwriting, typewriting, printing, photostating, photographing,
14 transmitting by electronic mail or facsimile, and every other means of recording
15 upon any tangible thing any form of communication or representation, including
16 letters, words, pictures, sounds, or symbols, or combinations thereof, and any
17 record thereby created regardless of the manner in which it has been stored.
18
19 DATED: The FROMSON LAW FIRM
20 PAUL D. FROMSON
Attorney for Demanding Party
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In re the Matter of Xxxxxx, Tiffany and David, Case No., 00000000

DEMAND FOR PRODUCTION OF DOCUMENTS SET NO. ONE (1)
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 1 DOCUMENTS TO BE PRODUCED
2 1. Each and every statement and any other documentation relating to all moneys
3 deposited in and withdrawn from any checking account (including trust and custodial accounts)
4 in any bank, savings and loan institution or depositary, credit union, or other savings institution
5 in your name solely, or jointly with any other person, or in which money has been deposited or
6 withdrawn for your benefit (any legal or equitable interest), for the period commencing January
7 1, 2018, through the date of responding.
8 2. Each and every statement and any other documentation relating to all moneys
9 deposited in and withdrawn from any savings account (including trust and custodial accounts) in
10 any bank, savings and loan institution or depositary, credit union, or other savings institution in
11 your name solely, or jointly with any other person, or in which money has been deposited or
12 withdrawn for your benefit (any legal or equitable interest), for the period commencing January
13 1, 2018, through the date of responding.
14 3. Each and every certificate of deposit, time certificate, savings certificate, or other
15 documents evidencing savings on deposit in your name solely, or jointly with any other person,
16 or in which money has been deposited or withdrawn for your benefit (including trust or custodial
17 accounts) for the period commencing January 1, 2018, through the date of responding.
18 4. Each and every stock certificate, bond, or other securities or documents relating to the
19 purchase, sale, exchange, or other form of conveyance of said stocks, bonds, or other securities
20 (including, but not limited to brokerage statements, confirmation slips, memoranda, books, and
21 records) standing in your name solely, or jointly with any other person, or standing in the name
22 of some other person and held for the benefit of you, for the period commencing January 1,
23 2018, through the date of responding.
24 5. Each and every statement and any other documentation relating to all moneys
25 deposited in and withdrawn from any investment account (including trust and custodial accounts)
26 in your name solely, or jointly with any other person, for the period commencing January 1,
27 2018, through the date of responding.
28 ////

In re the Matter of Xxxxxx, Tiffany and David, Case No., 00000000

DEMAND FOR PRODUCTION OF DOCUMENTS SET NO. ONE (1)
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 1 6. Each and every statement and any other documentation relating to any other bank,
2 financial institution, checking, savings, brokerage, or investment account of any kind not
3 previously disclosed in your Response to Requests for Production Numbers One through Five,
4 including trust and custodial accounts, whether held in your name solely or jointly with any other
5 person, for the period commencing January 1, 2018, through the date of responding.
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In re the Matter of Xxxxxx, Tiffany and David, Case No., 00000000

DEMAND FOR PRODUCTION OF DOCUMENTS SET NO. ONE (1)
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 PROOF OF SERVICE
1
2 I am a resident of the State of California, over the age of 18 years and not a party
to the within action. My business address is 1733 “O” Street, Merced, California 95340.
3
On August 1, 2024, I served the within documents:
4
5 DEMAND FOR PRODUCTION OF DOCUMENTS SET NO. (1)

6 BY FAX: by transmitting via facsimile the document(s) listed above to the

fax number(s) set forth below on this date before 5:00 p.m.
7
8 BY HAND: by personally delivering the document(s) listed above to the
person(s) at the address(es) set forth below.
9
ELECTRONIC MAIL: by transmitting via electronic mail the document(s)
10 listed above to the email address set forth below on this date before 5:00 p.m.
11 office@[Link]
12 BY MAIL: by placing the document(s) listed above in a sealed envelope
with postage thereon fully prepaid, in the United States mail at Merced,
13 California, addressed as set forth below.
14
BY PERSONAL DELIVERY: by causing personal delivery by
15 of the document(s) listed above the person(s) at the
address(es) set forth below.
16
17 Mr. David Xxxxxx II
C/o: Ms. Casey Aitchison
18 450 West 21st St, Suite A
Merced, California 95340
19
20 I am readily familiar with the firm's practice of collection and processing correspondence
for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same
21 day with postage thereon fully prepaid in the ordinary course of business. I am aware that on
motion of the party served, service is presumed invalid if postage cancellation date or postage
22
meter date is more than one day after date of deposit for mailing in affidavit.
23
I declare under penalty of perjury under the laws of the State of California that the above
24 is true and correct.
25
Executed on the Thursday, August 01, 2024 at Merced, California.
26
27 Alondra S. Manzo

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In re the Matter of Xxxxxx, Tiffany and David, Case No., 00000000

DEMAND FOR PRODUCTION OF DOCUMENTS SET NO. ONE (1)
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