Respondent Response to Request for Production of Documents

• •••12345678910111213141516171819202122232425262728requested in this paragraph that are in his possession, custody, and control, which aredescribed below.PayPal Transaction History for January 1, 2008 through November 9, 2011RESPONSE TO REQUEST NO. 7:Respondent objects to this request because it is vague and ambiguous.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documents requested do not exist.RESPONSE TO REQUEST NO. 8:Respondent objects to this request as being vague, ambiguous and overlyburdensome.Respondent also objects to this request because deposit informationhas been provided in previous responses to discovery propounded by discovery in theform of bank statements. In addition, some of the information requested is notavailable to Respondent, but may be available from the various institutions where hebanks.RESPONSE TO REQUEST NO. 9:Respondent objects to this request because it is not reasonably calculated tolead to the discovery of information relevant to the subject matter of this action nor tothe discovery of admissible evidence, and is therefore burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested is not in Respondent's possession. Theinformation requested should be available from CSldentity located at 7500 RialtoBlvd., #260, Austin, Texas 78735.RESPONDENTS RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX5

• •1• 2345678910111213• 141516171819RESPONSE TO REQUEST NO. 10:Respondent objects to this request because it is not reasonably calculated tolead to the discovery of information relevant to the subject matter of this action nor tothe discovery of admissible evidence, and is therefore burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested is not in Respondent's possession. Theinformation requested should be available from CSldentity located at 7500 RialtoBlvd., #260, Austin, TX 78735.RESPONSE TO REQUEST NO. 11:Respondent objects to this request because it is not reasonably calculated tolead to the discovery of information relevant to the subject matter of this action nor tothe discovery of admissible evidence, and is therefore burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this request•202122232425262728because the documentation requested is not in Respondent's possession. Theinformation requested should be available from CSldentity located at 7500 RialtoBlvd., #260, Austin, TX 78735.RESPONSE TO REQUEST NO. 12:Respondent objects to this request because it is not reasonably calculated tolead to the discovery of information relevant to the subject matter of this action nor tothe discovery of admissible evidence, and is therefore burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesRESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX6

• •1existed.234567891011121314• 1516171819202122232425262728RESPONSE TO REQUEST NO. 19:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Respondent responds as follows:Respondent is unable to comply with this request because he does not have access toany tax returns for CSldentity. In order to obtain the requested documentation,Petitioner will need to contact CSIdentity.RESPONSE TO REQUEST NO. 20:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Respondent responds as follows:Respondent is unable to comply with this request because he does not have access tothe documentation requested. In order to obtain the requested documentation,Petitioner will need to contact CSldentity.RESPONSE TO REQUEST NO. 21:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Respondent responds as follows:Respondent is unable to comply with this request because he does not have access toany tax returns for Internet Megameeting. In order to obtain the requesteddocumentation, Petitioner will need to contact Internet Megameeting.RESPONSE TO REQUEST NO. 22Respondent objects to this request because it is overly broad as to theexpansive timeframe requested and as such is not reasonably calculated to lead tothe discovery of information relevant to the subject matter of this action nor to thediscovery of admissible evidence, and is therefore burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locateRESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX9

1• 2345678910111213Respondent also objects to this request as being vague and ambiguous. Respondenthas made a diligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentresponds as follows: Respondent is unable to comply with this request because to hisknowledge the documents requested do not exist.RESPONSE TO REQUEST NO. 29:Respondent objects to this request because it is not reasonably calculated tolead to the discovery of information relevant to the subject matter of this action nor tothe discovery of admissible evidence, and is therefore burdensome and oppressive.Respondent also objects to this request as being vague and ambiguous. Respondenthas made a diligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right to•14151617181920212223242526amend this Response. Without waiving his objections to this request, Respondentresponds as follows: Respondent is unable to comply with this request because to hisknowledge the documents requested do not exist.RESPONSE TO REQUEST NO. 30:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Without waiving his objections to thisrequest, Respondent shall produce all documents requested in this paragraph that arein his possession, custody, and control, which are described below.A. Bank of America statements for account number 09073-41183 for theperiod of June 14, 2011 through October 12, 2011B. HSBC Premier statements for account number 843-00644-7 for the periodof August 24, 2011 through October 26, 2011• 2728C. Union Bank statements for account number 0801236977 for the period ofJune 7, 2011 through November 4, 2011RESPONDENTS RESPONSE TO PETITIONERS REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX12

• •1• 234567891011121314• 151617181920212223242526• 2728D. Union Bank statements for account number 0800043204 for the period ofJuly 1, 2011 through October 31, 2011RESPONSE TO REQUEST NO. 31:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Without waiving his objections to thisrequest, Respondent shall produce all documents requested in this paragraph that arein his possession, custody, and control, which are described below.A. Citi Platinum Select statements for account number ending 1758 for theperiod of June 2, 2011 to October 4, 2011B. Citi American Airline Advantage statements for account number ending2596 for the period of June 28, 2011 to October 28, 2011C. American Express TrueEarnings Business Card statements for accountnumber ending 7-51003 for the period of June 18, 2011 to October 21, 2011D. See response 1A for statements for Capital One account number ending -0631 dated May 17, 2011 through October 16, 2011.E. See response 1B for statements for Discover account number ending -2077dated July 3, 2010 through June 4, 2011.RESPONSE TO REQUEST NO. 32:Respondent objects to this request as being vague and ambiguous.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested is not in his possession if it exists at all.RESPONSE TO REQUEST NO. 33:Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forRESPONDENTS RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX13

1• 234567891011121314• 151617181920212223242526• 2728• •Production and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to responses served on August 22, 011, June 27,2011, May 7, 2010, July 15, 2009 and August 18, 2008. Respondent has made adiligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentshall produce all documents requested in this paragraph that are in his possession,custody, and control, which are described below.A. Earnings Statements from CSldentity Corporation for October 1, 2011through November 15, 2011B. Profit and Loss Statement — YTD for MJC Enterprises for January 1, 2011through November 22, 2011RESPONSE TO REQUEST NO. 34:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Without waiving his objections to thisrequest, Respondent responds as follows: Respondent is unable to comply with thisrequest because to his knowledge the documents requested do not exist.RESPONSE TO REQUEST NO. 35:Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forProduction and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to responses served on August 22, 011, June 27,2011, May 7, 2010, July 15, 2009 and August 18, 2008. Respondent has made adiligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentresponds as follows: See response to request number 33 above.RESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX14

• o1• 234567891011121314• 151617181920212223242526• 2728RESPONSE TO REQUEST NO. 36:Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forProduction and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to responses served on August 22, 011, June 27,2011, May 7, 2010, July 15, 2009 and August 18, 2008. Respondent has made adiligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentresponds as follows: See response to request number 30 above.RESPONSE TO REQUEST NO. 37:Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forProduction and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to responses served on August 22, 011, June 27,2011, May 7, 2010, July 15, 2009 and August 18, 2008. Respondent has made adiligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentresponds as follows: See response to request number 30 above. Also, bankstatements held by third parties such as CSIdentity, Internet Megameeting, DigitalInfrastructure, M Squared Enterprises, Immissary, etc. are not available toRespondent.RESPONSE TO REQUEST NO. 38:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Without waiving his objections to thisrequest, Respondent responds as follows: Respondent is unable to comply with thisRESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX15

• •1234567891011121314• 151617181920212223242526• 2728documentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentresponds as follows: See response to request number 31 above.RESPONSE TO REQUEST NO. 42:Respondent objects to this request as being overly-broad and not beingreasonably calculated to lead to the discovery of admissible evidence and as such isburdensome and oppressive. Respondent has made a diligent search andreasonable inquiry in an effort to locate the requested documentation. Discovery iscontinuing and the Respondent reserves the right to amend this Response. Withoutwaiving his objections to this request, Respondent responds as follows: Respondentis unable to comply with this request because to the best of his knowledge thedocuments requested do not exist.RESPONSE TO REQUEST NO. 43:Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forProduction and Inspection of Documents and is therefore burdensome andoppressive. Respondent has made a diligent search and reasonable inquiry in aneffort to locate the requested documentation. Discovery is continuing and theRespondent reserves the right to amend this Response. Without waiving hisobjections to this request, Respondent responds as follows: Petitioner is referred toRespondent's Response to Petitioner's Request for Production and Inspection ofDocuments — Set Four served on June 27, 2011 for a copy of the Residential LeaseAgreement dated August 14, 2009 (Response number 21A)RESPONSE TO REQUEST NO. 44:Respondent objects to this request as being vague and overly-burdensome.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,RESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX17

• •1• 234567891011121314• 151617181920212223242526• 2728Respondent responds as follows: Respondent is unable to comply with this requestbecause financial information belonging to third parties is not available to Respondent.RESPONSE TO REQUEST NO. 45:Respondent objects to this request as being overly-burdensome as to thetimeframe requested and as such is not reasonably calculated to lead to admissibleevidence. Respondent has made a diligent search and reasonable inquiry in an effortto locate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Without waiving his objections to thisrequest, Respondent responds as follows: Respondent is unable to comply with thisrequest because the documents requested are not in Respondent's possession.RESPONSE TO REQUEST NO. 46:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested is not available to Respondent.RESPONSE TO REQUEST NO. 47:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested either does not exist or is not available toRespondent.///RESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX18

• •1• 234567891011121314• 1516171819202122232425262728RESPONSE TO REQUEST NO. 48:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested either does not exist or is not available toRespondent.RESPONSE TO REQUEST NO. 49:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested either does not exist or is not available toRespondent.RESPONSE TO REQUEST NO. 50:Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forProduction and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to Respondent's Response to Petitioner's Requestfor Production and Inspection of Documents — Set Four served on June 27, 2011(Response 17A)RESPONSE TO REQUEST NO. 51:Respondent objects to this request as being overly-burdensome as to thetimeframe requested and as such is not reasonably calculated to lead to admissibleRESPONDENTS RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX19

• •1234567891011121314• 1516171819202122232425262728evidence. Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forProduction and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to responses served on August 22, 011, June 27,2011, May 7, 2010, July 15, 2009 and August 18, 2008. Respondent has made adiligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentresponds as follows: See responses to request numbers 30 and 31 above.RESPONSE TO REQUEST NO. 52:Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forProduction and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to responses served on August 22, 011, June 27,2011, May 7, 2010, July 15, 2009 and August 18, 2008. Respondent has made adiligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentresponds as follows: The documents requested have been lost or misplaced and areno longer available to Respondent. Petitioner is referred to Respondent's previousresponses for documents in Respondent's possession at the time of the responses.RESPONSE TO REQUEST NO. 53:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestRESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX20

• •12345678910111213• 14151617181920212223242526because the documentation requested does not exist.RESPONSE TO REQUEST NO. 54:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested does not exist.RESPONSE TO REQUEST NO. 55:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested either does not exist or is not available toRespondent.RESPONSE TO REQUEST NO. 56:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested either does not exist or is not in Respondent's•2728possession. The documents requested should be available from CSldentity located at7500 Rialto Blvd., #260, Austin, Texas 78735.RESPONDENTS RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX21

• •1234567891011121314• 151617181920212223242526RESPONSE TO REQUEST NO. 57:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested either does not exist or is not in Respondent'spossession.RESPONSE TO REQUEST NO. 58:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested either does not exist or is not in Respondent'spossession.RESPONSE TO REQUEST NO. 59:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Without waiving his objections to thisrequest, Respondent responds as follows: Respondent is unable to comply with thisrequest because the documentation requested does not exist.RESPONSE TO REQUEST NO. 60:Respondent objects to this request as not being reasonably calculated to lead•2728to the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locateRESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX22

the requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestbecause the documentation requested does not exist.Respectfully submitted,Dated: /1/;-//ieceak&ic-•CAROLE D. BALDWIN, Attorney forRespondent, MICHAEL J. CALDWELLRESPONDENTS RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX23

VERIFICATIONI, MICHAEL J. CALDWELL, hereby declare:I am the Respondent in the above entitled matter. I have read the foregoingRespondent's Response to Petitioner's Request for Production and Inspection ofDocuments - Set Six, and I declare under penalty of perjury under the laws of theState of California that the foregoing is true and correct.Dated:SIGNATURE VIA FACSIMILEMICHAEL J. CALDWELL, RespondentRESPONDENTS RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX24

123456789VERIFICATIONI, MICHAEL J. CALDWELL, hereby declare:I am the Respondent in the above entitled matter. I have read the foregoingRespondent's Response to Petitioner's Request for Production and Inspection ofDocuments - Set Six, and I declare under penalty of perjury under the laws of theState of California that the foregoing is true and correct.Dated: I I/ Z)liMICHAEL J. CALDWELL, Respondent1011121314e15161718192021222324252602728RESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX24

Respondent Response to Request for Production of Documents

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