Motion,Ex Parte: FD-2012-431

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IN Fé 5)
IN THE DISTRICT COURT OF PAYNE COUNTY Pays, 218 1c) court

STATE OF OKLAHOMA cute. Ong
IN RE THE MARRIAGE OF: JUN : LED “#homa
BRAD J. KASTL ) aye Lor, 19
Petitioner ) ,
) vere
and )
) Case No. FD-2012-431
LORI J. KASTL )
Respondent. )
)

MOTION TO PRODUCE
TO: Petitioner, BRAD J. KASTL:

Pursuant to the Oklahoma Discovery Code, 12 OS. §3224 et seq., Respondent submits
the following discovery requests to Petitioner. As used herein, the term “you” or “your” includes
you personally and, additionally, any agent, attorney, accountant, consultant or other person
acting or purporting to act for you or on your behalf, whether now or formerly.

In the event that privilege (including work product) is claimed concerning any question
or request made herein, please describe the nature of the privilege claimed; provide the name of
the person with whom such privilege is claimed; describe the information sufficiently to identify
and explain the basis for the privilege claimed; and if a document is claimed to be privileged
state the present location of the same and the names, addresses and telephone number of each
person who has seén the document before the date of these discovery requests.

Pursuant to'12 O.S. §3234, Respondent requests that Petitioner produce for Respondent’s
inspecting and/or copying, at the office of Respondent’s undersigned attorney, within thirty (30)

days following your receipt of these requests, the following:

Request for Production No. 1: Produce your 2018 tax return, or proof of 2018 income
if a return has not been filed, as well as your 2019 Year to Date income information.Approved By:

Verb Whe. Q

MELISSA DELACERDA, OBA # 2278
DELACERDA & OLIVER, ATTORNEYS AT LAW
301 South Duck

P.O. Box 1252

Stillwater, OK 74076

Telephone (405) 624-8383

Facsimile (405) 624-8385

Attorney for RespondentCERTIFICATE OF SERVICE

I do hereby certify that on the A Zz day of June, 2019, a true, correct and exact copy of the
above and foregoing instrument was:

Faxed

Hand-Delivered

y/ Mailed with proper postage thereon

Mailed via certified mail

To: _ Jill Ochs-Tontz
109 YN. Division
Guthrie, Oklahoma 73044
Attorney for Petitioner

Mm Ox h ur Q

MELISSA DELACERDA