LEGAL GUIDE
Written by attorney Robert Walter Dapelo | May 12, 2010

RIDER TO NOTICE FOR DISCOVERY AND INSPECTION for New York State

PLEASE NOTE that we will accept photocopies of documents, reserving the right to inspect any and all originals from which the copies were made, upon request.

PLEASE TAKE NOTICE that in the event any of the following information pertains to a business entity or entities, and an appraisal of the business entity or entitles is required, all of the information requested shall be furnished directly to the appraiser of that entity or entities.

  1. All savings bank books, passbooks, records and memoranda pertaining thereto, current as well as canceled, in the name of Defendant individually, jointly, or in trust or as custodian for any other person or persons.

  2. All savings bank books, passbooks, records and memoranda pertaining thereto, current as well as canceled, in the custody, possession or control of Defendant which are in the name of any other person or persons, and in which Defendant has an equitable, legal or other interest.

  3. All records and memoranda pertaining to all checking accounts, money market funds or other funds, any investment accounts, current as well an canceled, in the name of Defendant, individually, jointly or in conjunction with any other person or persons including check books, check book registers, canceled checks, check stubs and deposit slips.

  4. All records and memoranda pertaining to all checking accounts, money market funds or other funds, any investment accounts, current as well as canceled, in the custody, possession or control of Defendant in the name of any other person or persons, and in which Defendant has a legal, equitable, or other interest, including check books, check book registers, canceled checks, check book stubs, statement and deposit slips.

  5. All stock certificates, bonds, or other securities in the name of Defendant individually, or in conjunction with any other person or persons, or which may be held in the account of Defendant, individually, or in conjunction with any other person or persons, in any corporation, domestic or foreign, or issued by the Federal government, or by any state, municipality, or other governmental agency, including foreign governments.

  6. All books, records, accounts, monthly statements, statements of transactions, and all other papers and memoranda of stock brokerage accounts in the name of Defendant, individually, or in conjunction with any other person or persons.

  7. Copies of all Federal, State and city income tax returns of Defendant, together with all W-2s, 1099s, K-1s, 1065s, 1020s, 5500s, together with schedules and work sheets and all other papers, documents, and memoranda referring to any adjustment in or audit made in connection therewith. If a current tax return is on extension, include all W-2s, 1099s, K-1s, 1065s, 1020s, 5500s.

  8. Any and all contracts, current as well as canceled, for the rental of safe deposit boxes, in either a domestic or foreign location and all documents and papers pertaining thereto.

  9. Any and all records, documents, deeds, contracts, conveyances or papers relating to real property and/or personal property in the name of Defendant, individually or in conjunction with any other person or persons, or in which Defendant has any legal, beneficial or equitable interest.

  10. All records, papers, appointment books, diaries, account books, ledgers, balance sheets, income statements, cash receipt books and other documents and records pertaining to the income and earnings of Defendant including but not limited to wages, fees, profits, interest, return of capital, drawings, return of loans, bonuses, commissions, stock option grants, incentive earnings programs, severance pay, reimbursed expenses, sick pay, dividends, pension or retirement funds, profit sharing plans.

  11. All records, papers and memoranda, including but not limited to books, receipts, ledgers, bills, orders, in regard to any domestic and/or foreign company, companies or corporations, partnerships, joint ventures, or other business organizations in which Defendant has an interest, either individually or jointly with any other person or persons.

  12. All records, papers, memoranda, appointment books, diaries, account books, ledgers, cash receipt books, proofs of claim, canceled and/or any canceled checks pertaining to the income and earnings or anticipated income and earnings of Defendant from or on behalf of Defendant in any company that the Defendant has an interest, including but not limited to wages, consulting fees, bankruptcy claims, severance pay, bonuses, interest, return of capital, drawings, return of loans, commissions, reimbursed expenses, sick pay, dividends, pension or retirement funds, profit sharing and perquisites.

  13. Any and all records, papers, and memoranda pertaining to tax shelter investments in the name of Defendant, individually, or in conjunction with any other person or persons.

  14. Any and all records of personal or household expenses and disbursements.

  15. All records, monthly statements, credit card slips, papers and memoranda concerning credit card and/or charge accounts in the name of Defendant, individually, jointly, or in conjunction with any other person or persons, or of which Defendant has the use or is an authorized signatory including but not limited to statements, bills and record. of payments.

  16. Any and all policies of insurance covering Defendant, including but not limited to life insurance, endowment annuities, theft, floater, liability, health, accident, disability, business travel and automobile and all records showing payment of premiums therefor, as well as payment of claims.

  17. All records, including but not limited to income tax returns, stock books, minute books, general ledgers, payroll records and records of payment made to or for the account of Defendant on account of investments or ownership in any domestic or foreign company, corporation, partnership, business organization, or other venture, or ownership of any securities issued by such business entity.

  18. With respect to such corporations, partnerships, joint ventures or other business entities, produce all agreements to which Defendant is a party and all loans, personal expenses, disbursement and receipt accounts with respect to Defendant.

  19. Any and all records, documents and/or memoranda pertaining to retirement accounts, IRA's profit sharing plans, pension funds and/or annuities maintained by or on behalf of Defendant.

  20. All records pertaining to trips and vacations taken by Defendant, either individually or with others, including but not limited to dates when taken, bills, receipts and traveler's check purchases.

  21. All statements, records, bills, and the like, regarding all present debts owed by the Defendant.

  22. All records of Defendant's business expenses, including but not limited to bills, canceled checks and statements.

  23. All records of charitable contributions made by Defendant, including but not limited to bills, canceled checks and statements.

  24. All records, releases, documents and/or canceled checks, relating to any settlement of any litigation in which Defendant was a party.

  25. Any records, documents, deeds, contracts and papers relating to the sale or lease of property, owned by Defendant or in which Defendant has an interest.

  26. Any and all records, documents, papers and memoranda pertaining to monies owed by Defendant to others and/or monies owed to Defendant.

  27. A list of all assets transferred by the Defendant within the last five (5) years, and include the type and value of the asset, to whom transferred, amount received, if any, date of transfer, date monies were received, terms and conditions of said transfer and/or sale.

  28. copies of all Powers of Attorney as to which Defendant was either a principal or an agent.

  29. Title and Registration for each motor vehicle owned or operated by Defendant.

  30. Records, documents or other writings evidencing the current indebtedness of Defendant.

  31. United States or foreign passports, current and expired and any visas of Defendant.

  32. Copies of all loan and mortgage applications and financial forms to any bank or other lending organizations submitted by Defendant in the year referred to.

  33. Copies of all wills and trust agreements of which Defendant is a present income beneficiary or ultimate beneficiary.

  34. Copies of all medical, dental and disability reimbursement plans.

  35. Any and all leases of a residence or office in the name of Defendant individually, or in conjunction with any other person or persons.

  36. Any records of a gift or other transfer of property to anyone, by Defendant in excess of $250.00.

  37. Any records of a gift or other transfer of property from anyone to Defendant in excess of $250.00.

  38. Office or business diaries and appointment books.

  39. Records of Defendant's membership in private clubs and organizations, including records of payments made for dues, assessments, expenses, services and purchases made for liquor, food and any other items or articles.

  40. Any and all records, documents and/or memoranda pertaining to any investment and/or investments of the Defendant, either individually or with any other person(s) and/or any trust accounts.

  41. All records, bills, and/or statements pertaining to the purchase of jewelry, furs, automobiles, household furniture or furnishings, antiques, or luxury items by Defendant for himself/herself or any other person.

  42. Copies of any and all leases for each motor vehicle used by the Defendant, or any other person on behalf of the Defendant, for which the Defendant is paying.

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