STATE OF _____________ COUNTY OF _________ COURT OF ________ ) PETITION FOR EX PARTE ____________________ ) SUBPOENA OF LIMITED ) LIABILITY COMPANY RECORDS Plaintiff ) ) v. ) ) ____________________, LLC ) ) Defendant. ) ) ______________________________) PETITION FOR EX PARTE SUBPOENA OF LIMITED LIABILITY COMPANY RECORDS COME NOW, __________ and _____________, holders of more than ___ percent of the outstanding membership interest in ___________, a limited liability company organized under the laws of _____________ and Petitions the court, Ex Parte, this Court for an Order allowing issuance of a subpoena duces tecum for all [LLC Name] records including, but not limited to, all bank and financial records, minutes, contracts and correspondence. In support of this Petition it is represented that this Court has jurisdiction pursuant to )_________ and: I THAT ___________ and ___________ jointly own in excess of ____ percent of the membership interest of [LLC Name]. II THAT at the last membership meeting on [Date] Plaintiffs requested access to the entity records but were denied. III THAT entity's principal office is in __________, __________ County, ______________. IV THAT according to the records of the entity the management group of this limited liability company consists of ____________. V THAT no notice of any meetings have been provided to Petitioners since ________________. VI THAT Petitioners have been informed that the records are being kept by __________, secretary for said entity. VII THAT said entity has taken the following actions [list here why the records are needed]. VIII THAT Petitioners believe the management group, who are in possession and control of the entity records, have converted company assets for personal uses and have allowed a significant wasting of limited liability company assets. IX THAT Petitioners are concerned over the integrity of the business records of said limited liability company. X THAT ____________ of __________ should be authorized to seize, inventory and copy at a commercial copying business all financial accounting records including but not limited to bank records, canceled checks, bank statements, bank registers, operating agreements, minutes, entity records, correspondence and contracts. ______________ is to return said records within a reasonable time of copying same. XI THAT the court order, pursuant to §____ the limited liability company to pay the member's costs, including reasonable counsel fees, incurred to obtain the requested relief. WHEREFORE Petitioners request that the above relief be granted. _________________________ Petitioner