SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
FAMILY COURT
Domestic Relations Branch

REQUEST FOR PRODUCTION OF DOCUMENTS

Defendant, Frederick Shaddock, by and through his attorney, Robert R. Stone, submits the following requests, pursuant to Dom. Rel. SCR 34 or Maryland CPR 2-422, that the Defendant produce for inspection and copying the items and documents listed on the attached Schedule and file a written response to this Request within thirty days of service.

INSTRUCTIONS AND DEFINITIONS

1. Please identify each response by request number and segregate it from responses to other requests.

2. Identify each document withheld from production and state the grounds upon which you rely to withhold such production.  The identification should include the name of the author, each recipient of the document, its date, a brief description of the type of subject matter it contains and the particular privilege or immunity claimed.

3. The terms "item" or "document" or the plurals include any written, printed, typed, graphics, drawing or hand written, photo static, taped or recorded material or data or objects of any kind; and drafts, duplicates, carbon copies or copes thereof in the possession, custody or control of the Defendant or his agent or his counsel, including, without limiting the generality of the these terms, letters, correspondence, memoranda, notes, reports, statements, paraphrases of statements, tax records, papers, studies, contracts, records of telephone calls, invoices, suits, claims, pleadings or drafts thereof, photographs, tangible objects and any recordation of such matters, documents or objects; and including materials reflecting the method or means of communication thereof in the possession, control, or custody of Defendant or any of his agents, representatives or attorneys.

4. These requests for production of documents shall be deemed to be continuing, so as to require supplemental responses when you come into possession of information responsive to requests which has not previously been supplied in response to these requests for production of documents.  Such supplemental responses are to be served as soon as reasonably possible after the information is obtained.  The date such additional information comes into your possession shall be specified, and also the identity of the individuals who furnish such additional information to the person preparing the answer.

SCHEDULE OF REQUESTS

1. Individual federal, state, and local income tax returns and supporting schedules, Forms 1099, forms K-1 and Forms @-2, Forms W-4, estimated tax forms, extension requests and any other supporting documents for 2001 to the present.

2. All deeds and deeds of trust or similar documents, other security devices for any and all real estate in which you currently have or had any interest, whether direct or indirect and any and all agreements of any kind or nature with respect thereto, including but not limited to lease agreements.

3. Copies of any and all insurance policies owned by you.

4. All instruments, documents or records, including, without limitation, settlement sheets, receipts, bills of sale evidencing purchase or disposition of any assets in which you individually or jointly with anyone else have or have had any interest, including foreign assets, in Russia or any other foreign nation.

5. Copies of all monthly credit card statements for the period from January 1, 2001 to the present.  This is to include business credit cards which you used and personal credit cards in your name, or in the name of any other person or entity on which you have charged or advanced funds.

6. Copies of any and all financial statement prepared by you or on your behalf since 2001.  These are to include individual or joint personal statements as well as statements for any business, profession, corporation or professional corporation, in which you have or have had any interest, including, without limitation, the financial statement or date, or application submitted in connection with any real estate loan, mortgage, home loan or line of credit.

7. Evidence of any and all payments made to or received by you from any investment, employment, or profession for items other than salary or draw, to the extent not included in tax returns.

8. Evidence of any current debts

9. Copies of any and all documents illustrating income earned by you from property (real or personal) win which you have or have had any interest, direct or indirect.

10. Copies of any leases signed by you which currently remain in effect, and whether you have a lease, rental agreement or other evidence or proof of where you currently reside.

11. All books, calendars, diaries and other similar compilations maintained by you for personal, business or professional reasons from 2001 to the present.

12. All bank statements, cancelled checks, and check registered for any checking accounts in your name alone or jointly with any person or persons, firms, partnerships, company and/or corporation and/or limited partnership for the period from January 2001 to the present.

13. All employment contracts, documents and/or correspondence evidencing terms and conditions or employment between you and any employer during the period from 2010 to the present.

14. Copies of all plans of deferred compensation in which you are now a participant or in which you have been a participant at any time during the marriage to your spouse, including copies of pension plans, qualified and non-qualified retirement plans, profit sharing plans, Keogh plans, 401(k) plans, cash or deferred arrangements, stock option plans; and copies of summary plan description for each of such plan or deferred compensation, and copies of all documents and reports concerning your interest in the plans.

15. Documents, including regular payments, related to pension plans, retirement plans, 401K accounts, IRA accounts, and the like.

16. Copies of all instruments, documents or records evidencing sale, transfer or other disposition of any asset having a value of greater than $500.00, and indicate which asset was transferred or disposed of during the period of time.

17. Any and all documents, correspondence, emails, letters, tape recordings, photographs, and prepared exhibits which in any way support any fact, event, circumstance, or occurrence which you alleged contributed to the dissolution of your marriage to your spouse.

18. Copies of all instruments, documents, or recordings evidencing or being indicia of ownership of any other interest in any asset in which you had a legal, beneficial, or equitable interest during and which has not heretofore been produced in response to a preceding request, including but not limited to, bills of sale, certificates of title, and registrations of any real or personal property in which you have or have had a legal, beneficial or equitable interest.

Respectfully Submitted,

___________________________
Robert R. Stone, Esq.
PO Box 10041
Arlington, VA  22202
202-744-2618
DC Bar No. 139-032

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 2nd of June 2008, a copy of the foregoing REQUEST FOR PRODUCTION OF DOCUMENTS was sent via first-class postage prepaid to Robert Case Liotta, Esq. PO Box 100411, Arlington, VA  22201.