Notation: red means the documents will be provided and are located at the provided link
| RFP # | Documents requested | Response: | page# |
Location (of things we can produce at this time): |
| RFP-1 | Bank | Maurine records to 2008 - Sylvia Hamilton (previous Trustee) discovery ongoing | 1 |
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| RFP-2 | IRS | Contact agency-ongoing investigation | 1 |
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| RFP-3 | APD | Contact agency-ongoing investigation | 1 |
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| RFP-4 | DA | Contact agency-ongoing investigation | 1 |
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| RFP-5 | TDI | Contact agency-ongoing investigation | 2 |
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| RFP-6 | FINRA | Contact agency-ongoing investigation | 2 |
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| RFP-7 | SEC | Contact agency-ongoing investigation | 2 |
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| RFP-8 | embezzlement proof | 3 |
1) Randolph-Brooks bank records (receipt that we found in a box) 2) Chase Bank Records (transfers to Sylvia account from Maurine's) |
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| RFP-9 | written contract (DPOA) | Proponent has document(s) - but we will provide | 3 |
1) 2004 Davila Mystery DPOA 2) 1996 DPOA? |
| RFP-10 | attorney's fees docs | attorney-client privilege | 3 |
Jason Coomer |
| RFP-11 | recordings-photos anything basis of lawsuit | 3 |
discovery ongoing - criminal investigations pending | |
| RFP-12 | insurance | none | 4 |
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| RFP-13 | claims submissions | none - letter to Peggy Rodewald notifying Mutual of Omaha of embezzlement and requesting investigation and claim. | 4 |
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| RFP-14 | docs used to prepare answers | 4 |
included in Answers except where Proponent has document(s) | |
| RFP-15 | recordings of Davila | 3-10-2010 - already sent | 4 |
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| RFP-16 | recordings of Sylvia | ongoing investigation | 5 |
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| RFP-17 | exhibit list for trial | 5 |
see RFP-8, RFP-18, RFP-25 and other submitted documents. Discovery ongoing. Awaiting Defendants responses. See ROGs for attached documents and tables. TBD. | |
| RFP-18 | document for damages | 5 |
Annuity docs and spreadsheet | |
| RFP-19 | criminal convictions to be used at trial | ongoing investigations - TBD | 5 |
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| RFP-20 | court docs of other lawsuits | Sylvia Hamilton - available from District Court | 6 |
Be nice and just give this to them? Definitely should get RFA/RFP/ROGs to Sylvia on same day. |
| RFP-21 | police reports | Contact agency-ongoing investigation | 6 |
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| RFP-22 | docs proving causes of action | 6 |
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| RFP-23 | IRS communications and liens | Contact agency-ongoing investigation | 6 |
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| RFP-24 | all docs prepared by Davila | Propronent has document(s) | 7 |
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| RFP-25 | docs which defined duties of Davila which he breached-DPOA-emails | 7 |
DPOA-Emails-Letters Testamentary-IRS Sortable Tables and Summary Judgment Table(s) (short and long versions on Coomer webpage) | |
| RFP-26 | Wayne Gronquists duties | Not tax preparation or accounting services | 7 |
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| RFP-27 | witness statements obtained-Davila's ticker tape | Sylvia Hamilton and Davila already submitted with RFDs | 7 |
add 9/10/2008 ticker tape? |
| RFP-28 | tax returns 2000-2012 | Davila was supposed to produce non-fraudulent Trust taxes - instead produced 1040s hiding the embezzlement of the Trust from the IRS and the beneficiaries. Proponent has copies of these. | 8 |
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| RFP-29 | all bank account info of Maurine Hamilton (bank acct list given a thru i) | Sylvia Hamilton discovery ongoing - see embezzlement proof bank records above | 8 |
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| RFP-30 | Probaitcourt.com | proprietary, attorney-client privilege, work product, private | 8 |
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| RFP-31 | PBC | proprietary, attorney-client privilege, work product, private | 8 |
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| RFP-32 | PBC | proprietary, attorney-client privilege, work product, private | 9 |
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| RFP-33 | APD - copy of police report - 2 of them | Contact agency-ongoing investigation | 9 |
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| RFP-34 | APD | Contact agency-ongoing investigation | 9 |
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| RFP-35 | APD | Contact agency-ongoing investigation | 9 |
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| RFP-36 | APD | Contact agency-ongoing investigation | 9 |
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| RFP-37 | APD | Contact agency-ongoing investigation | 10 |
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| RFP-38 | APD | Contact agency-ongoing investigation | 10 |
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| RFP-39 | from Gronquist to Davila documentation | Propronent has document(s) | 10 |
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| RFP-40 | from Davila to Gronquist documentation | Propronent has document(s) | 11 |
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| RFP-41 | from Alan to Davila | Propronent has document(s) | 11 |
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| RFP-42 | from Davila to Alan | Propronent has document(s) | 11 |
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| RFP-43 | from Maurine to Davila | Propronent has document(s) | 12 |
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| RFP-44 | from Davila to Maurine | Propronent has document(s) | 12 |
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| RFP-45 | from Sylvia to Maurine | Sylvia Hamilton discovery ongoing | 13 |
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| RFP-46 | from Maurine to Sylvia | Sylvia Hamilton discovery ongoing | 13 |
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| RFP-47 | from Estate of Maurine to Davila | Propronent has document(s) | 13 |
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| RFP-48 | from Davila to Estate of Maurine | Propronent has document(s) | 14 |
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| RFP-49 | from Estate of Alfred to Davila | Propronent has document(s) | 14 |
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| RFP-50 | from Davila to Estate of Alfred | Propronent has document(s) | 15 |
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| RFP-51 | settlement docs with Sylvia | none | 15 |
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| RFP-52 | Probate docs | available at Probate Court online | 15 |
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| RFP-53 | accounting/confession of Sylvia | already submitted | 15 |
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| RFP-54 | copy of Davila's 4/14/2009 "Hamilton Tax Folder" | Propronent has document(s) | 15 |
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| RFP-55 | anything not requested which has to do with liability or damages which will be submitted to jury | 16 |
email from Brad Seals? |