STATE OF _____________ COUNTY OF _________ COURT OF ________ ) ) ) Plaintiff ) ) v. ) ) ____________________, LLC ) ) Defendant. ) ) ______________________________) ____________________ Request for Production of Documents
REQUEST FOR PRODUCTION Plaintiff requests that Defendant LLC produce to or permit the inspection and copying by Plaintiff's counsel of each of the following documents or things: 1. The operating agreement of Defendant LLC.
2. The employment agreements between Defendant LLC and any person who is or was also an officer, manager or member of Defendant LLC. 3. All minutes, resolutions, buy-sell agreements, membership lists, transfer ledgers and any other document within the possession or control of the official record custodian which evidences or references any and all official actions taken by Defendant LLC since the date of its organization. 4. All state and federal tax returns, schedules and reports filed by Defendant LLC since the date of its organization. 5. All financial statements, loan applications and profit and loss statements prepared for Defendant LLC since the date of its organization.
6. Any and all notes, checks, invoices or other documentation which reflect the payment of obligations of a member, officer, or manager of Defendant LLC by Defendant LLC. 7. Any and all notes, checks, invoices or other documentation which reflect the payment of obligations of Defendant LLC by a member, officer, or manager of Defendant LLC. 8. Any and all notes, guarantees, invoices or other documentation reflecting loans made to, or obtained by, Defendant LLC. DATED: __________________