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

Case 1:04-cv-00125-RPM-CBS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-0125-RPM-CBS UNITED STATES OF AMERICA, Plaintiff, v. 770 LOOP ROAD, LEADVILLE, COLORADO 80461, $10,846.00 IN UNITED STATES CURRENCY, $6,546.06 IN UNITED STATES CURRENCY, Defendants.

REQUEST FOR PRODUCTION OF DOCUMENTS - SCOTT GORDON

PLEASE TAKE NOTICE that the undersigned counsel for Plaintiff the United States, pursuant to Fed.R.Civ.P. 30(b)(5) and 34, hereby requests that you bring to your September 6, 2005 deposition, the following documents: 1. income since 1995. 2. Documents evidencing all dealings with financial institutions, including Documents evidencing and confirming any and all employment and

but not limited to Commercial Bank of Leadville, Community First Bank of Littleton, People's Bank of Leadville, and Alpine Bank of Copper Mtn., including but not limited to account opening and closing documents, deposit slips, checks, monthly statements, and safe deposit box records. 3. All documents evidencing the initial purchase, subsequent financing, and

maintenance and improvement of, defendant 770 Loop Road, including but not limited to

Case 1:04-cv-00125-RPM-CBS

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purchase closing documents, Warranty Deed, Deed of Trust, monthly statements, and bills for and payments of repairs, and improvements. 4. All documents evidencing the purchase and operation of marijuana

growing and cultivating materials and equipment, including but not limited to purchase orders, bills of sale, sales receipts, and records of sales or transfers of marijuana by or from you. 5. All documents evidencing your possession of defendant $10,846.00 in

U.S. Currency, including but not limited to the sale of a KTM motorcycle, a 1971 Ford truck, a monoski, a horse trailer, two saws, a Honda XR350, and two monoskis, as alleged in your previous response to Interrogatory No. 12. 6. 7. 2003. 8. All documents relating to the founding, set up, organization, and operation All documents evidencing your loan from Shane Cates. All documents evidencing your trip to Shane Cates' house in September of

of Chronic Ski Company, including all financial documents relating to the company. 9. All documents identifying Jason Frydl, Mike Yenter, Walt Stephans, and

Shane Cates, including full names, addresses, phone numbers, e-mail contacts, and all documents evidencing all contacts and dealings you have had with each. 10. All documents relevant to your claim and defenses in this case, and all

documents to which you referred for the purpose of responding to Plaintiff's First Set of Interrogatories and Request for Production of Documents, as promised in your previous Response to Interrogatory No. 13. 11. All documents to which your referred for the purpose of preparing for the

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September 6, 2005 deposition. Dated this 26th day of August, 2005. Respectfully submitted, WILLIAM J. LEONE United States Attorney

s/ James S. Russell JAMES S. RUSSELL Assistant United States Attorney 1225 17th Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 FAX: (303) 454-0402 E-mail: [email protected] Attorney for Plaintiff

CERTIFICATE OF SERVICE I hereby certify that on this 26th day of August, 2005, the foregoing REQUEST FOR PRODUCTION OF DOCUMENTS - SCOTT GORDON was mailed, postage pre-paid, to: Dennis W. Hartley, Esq. 1749 South Eighth Street, Suite 5
Colorado Springs, Colorado 80906 Counsel for claimant Scott Gordon

s/ Nicole C. Davidson Nicole C. Davidson Office of the United States Attorney