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SUBPOENA
SUMMIT COUNTY COMMON PLEAS COURT
CLV. RULE 48
Sean Garnet Todd
CASE NO.
2024 00 0006
PLAINTIFF
23102887
Ys. FOREIGN CASE NO.
Christine Lynn Todd (if applicable) SUBPOENA IN CIVIL CASE
DEFENDANT
Charlotte Ruble, Esq.
ATTORNEY/PRO SE:
11475 Great Oaks Way
Suite 125
ADDRESS: Alnharetta GA 2nn??
678 879 9000
Gary Ebby PHO!
TO: (NAME)
1120 Nina Ln,
(ADDRESS) SUPREME CT. NO.
Akron, OH 44333
(CITY, STATE, ZIP)
YOU ARE HEREBY COMMANDED TO
ATTEND AND GIVE TESTIMONY AT A (TRIAL)(HEARING)(DEPOSITION) ON THE
February 930AM 388 South Main St. Akron
DATE 22, 2024 TIME:, piace; Suite 440
x PRODUCE DOCUMENTS, ELECTRONICALLY STORED INFORMATION, OR TANGIBLE THINGS AT
TRIAL,HEARING OR DESPOSITION.
> _ PRODUCE AND PERMIT INSPECTION AND COPYING OF ANY DESIGNATED DOCUMENTS OR
ELECTRONICALLY STORED INFORMATION THAT ARE IN YOUR POSSESSION, CUSTODY, OR CONTROL.
> PRODUCE AND PERMIT INSPECTION AND COPYING, TESTING, OR SAMPLING OF ANY TANGIBLE THING
THAT ARE IN YOUR POSSESSION, CUSTODY, OR CONTROL.
2X PERMIT ENTRY UPON DESIGNATED LAND OR OTHER PROPERTY THAT IS IN THE POSSESSION OR
CONTROL OF YOU FOR THE PURPOSES DESCRIBED IN CIV. R. 34(A)(3).
See ExhibitA enclosed.
DESCRIPTION OF ITEMS TO BE PRODUCED: .
HEREOF FAIL NOT UNDER PENALTY OF THE LAW WITNESS MY SIGNATURE AND SEAL OF SAID COURT, THIS
week we
TAVIA GALONSKI ° Seow OF: LEV
ve a7.
) 20,
. Check, ger Ne2 olay ~
SUMMIT COUNTY CLERK OF COURTS : wr
ox DeputYeRik *
RETURN OF SERVICE. Isis -4
Received this Subpoena on the day of 20__at M. and
oa the day of. 20_,at
M.,, I served the same upon by delivering to.
Personally or Residential a true copy of this subpoena.
Sheriff-Attorney-Process Server-Notary
Mileage: miles@ ; TOTALS
PROTECTION OF PERSONS SUBJECT
TO SUBPOENAS:
L A party or an attomey responsible for the issuance and service of a subpoena sliall take reasonable steps to avoid
imposing undue burden or expense on a person subject to that subpoena.
2. {a)A person commanded to produce under divisions (A)(1)(0)(i), (ii), (iv) oF (v) ofthis rule need not appearin person
at the place of prod ion or inspection unless commanded to attend and give testimony at a deposition, he: or trial,
(b) Subject to division (D)(2) of this rule, a person commanded to produce under divisions (AX1)(b)(i) li) iv), or (v)
of this rule may, within fourteen days after service of tlie subpoena or before the time specified for compliance if such time
is less than fourteen days after service, serve upon the party or attorney designated in the subpoena written objectioas to
production. If objection is made, the party serving the subpoena shall not be entitled to production except pursuant to an
order of the court by which the subpoena was issued. If objectionhas been made, the party sexving the subpoena, upon
notice to the person commanded to produce may move at any time for an orderto compel the production, An order to
compel production shall protect any person who is not a party or an officer of a party from significant expense resulting
from the production commanded.
3.0n timely motion, the court from which the subpoena was issued shall quash or inodify the subpoena, or order
appearance or production only under specified conditions, if the subpoena does any of the following — Fails to allow
reasonable time to comply; requires disclosure of privileged or otherwise protected matter and no exception or waiver
applies; requires disclosure of a fact known oropinion held by an expert not retained or specially employed by aay party in
anticipation of litigation or preparation for trial as desctibed by CIV R. 26(B)(4), if the fact or opinion does not describe
specific events or occurrences in dispute and results from study by the expert that was not made at request of any patty;
subjects a person to undue burden.
4. Before filing a motion pursuant to division (C) (3) (d) of this rele, a person resisting discovery under this rute shall
attempt to resolve any claim of undue burden through discussions with the issuing attomey. A motion filed pursuant to
division (C) 3)(d) ofthis rule shall be supported by an affidavit ofthe subpoenaed person or a certificate of that person's
attorney of the efforts made to resolve any claim of undue burden.
5. If amotion is made under divisiom(C}(3Y(c) or (C\3)(A) of this rule, the court shall quash or modify the subpacaa unless
the party in whose behalf the subpoena is issued shows a substantial need for the testimony or material that cannot be
otherwise met without undue hardship and assures that the person to whom the subpoena is addressed will be reasonably
compensated.
DUTIES IN RESPONDING TO SUBPOENAS:
1. A person responding to a subpoena to produce documents shall, at the person's option, produce them as they are kept
in the usual course of business or organized and labeled to correspond with the categories in the subpoena. A person
producing documents or electronically stored information pursuant to a subpocna for them shall permit their
inspection and copying by all parties present at the time and place set in the subpoena for inspection and copying.
2 Ifa request does not specify the form or forms for producing electronically stored information, a person responding to
a subpoena may produce the information in a form or forms in which the information responding is ordinarily
maintained if that form is reasonable useable, or in any form thal is reasonably useable, Unless ordered by the court
or agreed to by the person subpoenaed, a person responding to a subpoena need not produce the same electronically
stored information in more than one form.
‘A person need not provide discovery of electronically stored information when the production imposes undue burden
or expense. On motion to compel discoveryor for a protective order, the person from whom electroaically stored
information is sought must show that the informationis not reasonably accessible because of undue burden or
expense. Ifa showing of undue burden or expense is made, the court may nonetheless order production of
electronically stored information ifthe requesting patty shows good cause. The court shall consider the factors in
Civ. R. 26(8)(4) when determining if good cause exists, In ordering production of electronically stored information,
the court may specify the format, extent, timing, allocation of expenses and other conditions for discovery of the
electronically stored infonnation.
When information subject to a subpoena is withheld on a claim that it is priviteged or subject to protection as trial
preparation materials, the claim shall be made expressly and shall be supported by a description of the nature of the
documents, communications, or things not produced that is sufficient to enable the demanding party to contest the
claim,
5. Ifinformation is produced in response to a subpoena that is subject to a claim af privilege or of protection as trial-
preparation material, the person making the claim may notify any party that recelved the information of the claim and
‘the basis for it. After being notified, a receiving party must promptly return, sequester, or destroy the specified
information and any copies within the party's possession, custody or control. A party may not use or disclose the
information until the claim is resolved. A receiving party may promptly present the information to the court under
seal for determination of the claim of privilege or of protection as trial-preparation material. If the receiving party
disclosed the information before being notified, it must take reasonable steps to retrieve it. The person who produced
the information must preserve the information until the claim is resolved,
SANCTIONS:
AL, Failure by any person without adequate excuse to obey a subpoena served upon that person
may be deemed contempt of the court
from which the subpoena issued. “A subpoenaed person or that person's attomey who fiivolously resists discovery under this rule may
be required by the court to pay the reasonable expenses, including reasonable attorney's fees ofthe party seeking discovery. The court
from which a subpoena was issued may impose upon a party or attomey in breach of the duty imposed by division (C)(4) of this rule
an appropriate sanction, which may includa, but is not limited to, lost eamings and reasonable attomey's fees.
2024 00 0006
IN THE SUPERIOR COURT OF COBB COUNTY
STATE OF GEORGIA
SEAN GARNET TODD,
PLAINTIFF, CIVIL ACTION FILE NO. 23102887
vs.
CHRISTINE LYNN TODD,
DEFENDANT.
\ EXHIBIT A - SUBPOENA OF GARY EBBY
DEFINITIONS
As used herein, the terms listed below are defined as follows:
1. A “Document” includes, by way of illustration, but not by way of limitation, the
following items which are within the possession, custody or control of the Mr. Gary
Ebby or his agents, employees, servants, officers, representatives, attorneys, and
any other Person acting on his behalf, whether individually or collectively, who have
obtained, or who ‘are ina position to obtain, information for or on behalf of the Mr.
Gary Ebby, including both copies -and originals, unless otherwise stated: letters;
reports; agreements; communications; internal company communications; original or
Preliminary notes; correspondence; telegrams; radiograms; telex messages;
memoranda; summaries or records of telephone conversations; routing slips or
memoranda; calls or service reports; audibly reproducible recording on tape, disc or
the like; computer printouts; microfilm; microfiche; summaries or records of Personal
interviews and conversations; diaries; forecasts; statistical statements; graphs;
drawings; positive and negative prints of pictures, motion or still, including excised
frames of motion pictures; minutes or records of conferences and meetings,
:XHIBIT A — SUBPOENA OF GARY EBB"
Sean Toddv. Christine Todd, Superior Court of Cobb County; CAFN: 23102887
Page 1 of 19
including meeting of directors, executive committees, financial committees; financial
statements; lists of Persons attending meetings or conferences; expression or
statements of policy; reports or summaries of interviews; reports or summaries of
investigations; opinions or reports of consultants and/or investigators; patent,
trademark or copyright searches; opinions of counsel records or summaries of
negotiations; contracts or agreements; brochures; pamphlets; catalogs;
advertisements; circulars; trade letters; press or publicity releases; drafts of any
Documents; revisions or drafts of any Documents; stenographic or graphic material
in whatever form, including drafts and reproductions.
For purposes of this request, any Document bearing on any sheet or side thereof
any marks such as initials, stamped indicia, comment or notation, of any character
and not part of the original Document or photographic reproduction thereof, every
copy of such writing or record with the originals not in Mr. Gary's possession,
custody or control; and every copy of every such writing or records where such copy
is not an identical copy of an original or where such copy contains any commentary
or notation whatsoever, which does not appear in the original, is to be considered
and identified as a separate Document.
2. “Income” or "Gross Income" is defined per O.C.G.A. §19-6-15 (f).!
3. “Person” means any individual, firm, company, corporation, partnership,
proprietorship, joint venture, association, governmental agency, organization, group
1 The definition of “Income” under 0.C.G.A. §19-6-15(f) is broader than “Income” as defined by state and federal tax
laws.
XHIBIT A ~ SUBPOENA OF GARY EBBY
Sean Todd v. Christine Todd Superior Court of Cobb County; CAFN: 23102887
Page 2 of 19
of Persons, or any other entity. When asked to identify a "Person" who is any
"individual" in an official position with a "firm, company, corporation, partnership,
proprietorship, joint venture, association, governmental agency, organization, group
of Persons, or any other entity," you should identify both the "individual" and that
Person's relationship with the “firm, company, corporation, partnership,
proprietorship, joint venture, association, governmental agency, organization, group
of Persons, or any other entity.”
“You,” and “Your,” refers to Mr. Gary Ebby, and his agents, employees, servants,
officers, representatives, attorneys, and any other Person acting on his behalf,
whether individually or collectively, who have obtained, or who are in a position to
obtain, information for or on behalf of the Mr. Gary Ebby.
“Petitioner” refers to Mr. Todd Sean, the Petitioner in this action.
“Respondent” refers to Ms. Christine Todd, the Respondent in this action.
“Answer” means the defensive pleading filed by the Respondent to the Petitioner's
Complaint for Divorce, as it may be amended hereafter.
Terms in the singular shall be deemed to include the plural and vice versa. Terms
importing the masculine gender may be applied to females or organizations.
DOCUMENTS TO BE PRODUCED
EVIDENCE OF INCOME
EXHIBIT A — SUBPOENA OF GARY EBBY
Sean Todd v. Christine Todd, Superiar Court of Cobb County; CAFN: 23102887
Page 3 of 19
1
All pay stubs, statement of earnings, W-2 forms, 1099 forms, K-1 forms, and any
other Documents evidencing any Income or funds you earned or received, directly or
indirectly, whether from employment, distributions, gifts, loans or otherwise, within the
last three (3) complete years and year to date, until the final trial in the above-styled
case. Documents shall include, but are not limited to, financial statements, bank
statements, statements of accounts receivable and payable, and other evidence of
Income from business operations, work as an independent contractor’or
consultant, sales of goods and services, and rental properties, less ordinary and
Teasonable expenses necessary to produce self-employment Income, loan
documents, including but not limited to Promissory Notes or other writings, and
any documents reflecting receipt of gift funds.
2.
Evidence of all self-employment income for the past three (3) years. This shall
include, but not be limited to, financial statements, bank statements, statements of
accounts receivable and payable, and other. documents relating to income from
business operations, work as an independent contractor or consultant, sales of goods
and services, and rental properties.
3
If you earn or have earned self-employment income at any time during the past
three (3) full calendar years, please produce any and all evidence of your ordinary and
reasonable business expenses necessary to produce such self-employment income.
EXHIBIT A — SUBPOENA OF GARY EBBY
Sean Todd v. Christine Todd, Superiar Court of Cobb County; CAFN: 23102887
Page
4 of 19 .
TAXES
4
All Income tax returns that you filed or that have been filed on your behalf,
whether individually and/or jointly with any other Person or entity, with any federal or
state government in the past three (3) years and all succeeding years during the
pendency of the above-styled case. Your Tesponse should include all schedules,
worksheets, W-2, 1099, K-1s from any partnerships, Sub-S corporations or trusts, and
any other Documents prepared by you, your accountant, or provided to you by your
employer or any other Person or entity, pertaining to the taxable years requested. If the
filing date of any return has been extended or you are otherwise late in your required
filing, identify each return and explain why said return has not been filed.
5
If any state or federal Income tax returns for the last three (3) years have not
been prepared or filed, please produce all copies of any tax source Documents (i.e.: W-
2, 1099 and K-1} you have received or prepared on your behalf.
6
All Documents, including, but not limited to, notices, statements and/or bills,
reflecting any taxes paid or owed, or unpaid but owing and any liens by any taxing
authority on any business or property, tangible or intangible, you control, own, or in
which you have any interest or equity in that you have received within the last three (3)
complete years and year to date, until the final trial in the above-styled case.
EXHIBIT A — SUBPOENA OF GARY EBBY
Sean Toddv. Christine Todd, Superior Court of Cobb County; CAFN: 23102887
Page 5 of 19
7.
All declarations of estimated income tax filed by you or on your behalf with the
Internal Revenue Service for the past three (3) years.
FRINGE BENEFITS
8
All Documents and records evidencing any fringe benefits available to you from
any business or entity in which you are an employee or in which you have any legal or
equitable ownership interest, including, but not limited to, auto expense, travel expense,
telephone, Personal living and entertainment expense such as meal reimbursement or
per diem, bonuses, health, accident, dental and hospital insurance.
EXPENSE REIMBURSEMENT
9.
All Documents, receipts and vouchers reflecting funds you received or to which
you are entitled to receive, directly or indirectly, for reimbursement or payment of
expenses, from yourself (if self-employed), your employer or any other Person or entity
within the last three (3) complete years and year to date, until the final trial in the above-
styled case.
- SOCIAL SECURITY STATEMENT
10.
A copy of your Social Security Earnings statement for the last calendar year.
EXHIBIT A~ SUBPOENA OF GARY EBB’
Sean Todd v. Chnsine Tod SI juperior Court of Cobb County; CAFN: 23102887
Page 6 of
OTHER INCOME
11.
All Documents and records of social security payments, disability payments, and
retirement benefits to which you have received or are entitled to receive for yourself or a
dependent within the last three (3) complete years and year to‘date, until the final trial in
the above-styled case. Provide statements, notifications, award letters, your most recent
annual statement and any other Documents relating to your current or future retirement
or disability benefits from any Person, entity and/or the Social Security Administration.
CREDIT CARDS
12.
Produce all statements, receipts and all other Documents evidencing charges
incurred, payments made and the balance due on all unsecured debt, including but not
limited to any credit cards, credit lines and charge accounts, whether the account is
open or closed, that are or have been maintained in your name individually ‘or jointly
with any other Person or entity, including Ms. Christine Todd, or for which you are or
were an authorized signatory within the last three (3) complete years and year to date,
until the final trial.in the above-styled case.
ACCOUNTS
13.
All records of bank checking accounts, savings accounts, cash management
accounts, certificates of deposit, investment and money market accounts maintained by
you, individually and/or jointly with others, or maintained by you as trustee or custodian
EXHIBIT A — SUBPOENA OF GARY EBBY
Sean Tadd v. Christine Todd; Superior Court of Cobb County; CAFN: 23102887
Page
7 of 19
for any other person or persons, including but not limited to monthly bank statements,
cancelled checks, deposit slips, check registers, passbooks, statements relating to
savings accounts, certificates of deposit, and any other such records for the past three
(3) years and continuing to the date of trial of the above-styled case. .
14.
All copies of personal financial and net worth statements submitted by you,
individually and/or jointly with any other person or persons, to any bank or lending
institution for the past three (3) years.
15.
Any and all applications for credit, bank accounts, loans or other financial
products of any nature whatsoever which you have submitted to any person or
institution for the past three (3) years.
16.
Any and all notes, installment obligations, lines of credit, home equity loans, and
other obligations of any nature whatsoever of which you are currently an obligor,
individually and/or jointly with any other person or persons. If there are monthly
statements or check registers relating to any loan account, please produce these
records for the past three (3) years.
17.
Any and all notes or obligations of any nature whatsoever of which you are
currently an obligee, individually and/or jointly with any other person or persons.
EXHIBIT A - SUBPOENA OF GARY EBBY
Seari Tedd v. Christine Todd, Superior Court of Cobb County; CAFN: 23102887
Page
8 of 19
18.
Any and all notes, installment obligations, or other obligations with a principal
amount of $1,000 or more (excluding charge account or credit cards) of which you were
an obligor, individually and/or jointly with any other person or persons in the past three
(3) years,or any time thereafter, but of which you are no longer an obligor or joint
obligor.
19. ‘
Any and all monthly credit and charge statements and receipts showing all
charges and payments made and the balance due on any credit cards or charge
accounts maintained by you or regularly used by you, including but not limited to, any
accounts maintained in your name or yourself together with other person or entity, for
the past three (3) years.
20.
All partnership tax returns and corporate tax returns filed with the Federal and
State governments for any partnership, corporation, or association of which you were a
partner or stockholder for the past three (3) years.
21.
Any and all monthly, quarterly, or annuai cash flow summaries, profit or loss
statements, or income statements of any nature for any partnership, corporation, or
association of which you are a partner or a stockholder for the past three (3) years.
EXHIBIT A —- SUBPOENA OF GARY EBBY
Sean Toddv. Christine Todd, Superior Court
of Cobb County; CAFN: 23102887
Page 9 of 19
22.
Any and all balance sheets or statements of assets and liabilities for any
partnership, corporation, or association of which you are a partner or a stockholder for
the past three (3) years.
23.
Any partnership agreements, stockholder agreements, buy-sell agreements or
other agreements. of any nature relating to any partnership, corporation, or other
business entity in which you have an interest.
24.
Any and all checking and savings account records, and records of any money
market accounts or other investment accounts, maintained in connection with any
partnership, corporation, or association of which you are a partner or a stockholder, for
the past three (3) years.
25.
Any and all minute books of any corporation in which you have any interest.
INVESTMENTS AND OTHER SECURITIES
26.
Ali Documents evidencing control, ownership or interest ih any securities, stocks,
stock options or grants, investments, mutual funds, liquid asset funds held personally or
through any entity (foreign or domestic), whether held individually or jointly with any
other Person or entity, within the last three (3) complete years and year to date, until the
final trial in the above-styled case. Documents include, but are not limited to,
certificates, statements, tax source Documents, notices and disclosures.
EXHIBIT A~ SUBPOENA OF GARY EBBY
Sean Todd v. Christine Todd, Superior Court of Cobb County; CAFN: 23102887
Page 10 of 19
RETIREMENT
27.
All Documents, records, statements and any other tangible evidence relating to
any interest you have or had in any retirement plans, including but not limited to
annuities, profit sharing plans, pension plans, savings plans, thrift saving plans, Keogh
plans, Individual Retirement Accounts, 401(k) plans, 401(a) plans, 403(b) plans, cash or
deferred compensation plans or any other retirement accounts or plans of any nature
whatsoever in which you have an interest, whether or not any such plan is qualified
pursuant to the Internal Revenue Code of 1954, as amended, or unqualified within the
last three @) complete years and year to date, until the final trial in the above-styled
case.
NET WORTH STATEMENTS AND CREDIT APPLICATIONS
28.
All financial net worth statements and credit applications you, some other Person
or entity on your behalf or any entity in which you have any interest or control prepared
or submitted to any bank, lending institution or to any Person or entity, from January
2021 until the date of final trial in the above-styled case.
LIABILITIES
29.
All notes, installment obligations, lines of credit, home equity loans, and any
other Documents or evidence, including, but not limited to, monthly statements, check
tegisters, loan payment books, coupon books, reflecting any obligation, of any nature
whatsoever, for which you are or were obligated in any manner, whether individually
EXHIBIT A - SUBPOENA OF GARY EBBY
Sean Todd v. Christine Todd; Superior Court of Cobb County; CAFN: 23102887
Page11 of 19
and/or jointly with any other Person or entity within the last three (3) complete years and
year to date, until the final trial in the above-styled case.
REAL PROPERTY
30.
Please produce the following Documents from January 1, 2021 onward until the
date of final hearing or trial of this case:
a) Any and all Documents, memoranda, closing statements or writings evidencing
any interest you have, had or may acquire in real property, whether as owner, co-
owner, fiduciary, trust beneficiary (vested or contingent), partner, limited partner,
shareholder, joint venturer, mortgagee, developer, manager of otherwise. This
request includes but is not limited to any Wills, Trusts, Deeds, Settlement
Statements (also known as a HUD-1 statement), any closing documents, or any
other documents evidencing your acquisition or interest in the property;
b) Copies of all Documents reflecting real estate mortgages held by you or by any
trust, business or entity in which you have or had a present or contingent interest;
¢) Any evidence showing all contributions in cash or otherwise made by you, Ms.
Christine Todd, a Third person, or any entity you own or in which you have an
interest in to the acquisition any real property or mortgages identified in
subsection (a) and (b) above; and
qd) All Documents pertaining to real estate leases (including lease purchase
agreements), whether you or any entity in which you own, control or in which you
have an interest in are listed as lessor or lessee.
EXHIBIT A — SUBPOENA OF GARY EBBY
Sean Todd v. Christine Todd, Superior Court of Cobb County; CAFN: 23102887
Page 12 of 19
BUSINESS INTERESTS
31.
With respect to any firm, trust entity, partnership, limited partnership, company,
corporation, venture, sole proprietorship or any other business or legal entity of any
“kind, in which you own, control, have a financial interest in or from which you receive or
will be receiving any Income or compensation, produce the following Documents:
a) Complete federal, state and any other government tax returns (including any
source Documents, schedules, exhibits and forms) of any kind that have
been prepared and/or filed for the last three (3) years;
b) Annual balance sheets and profit and loss statements and quarterly,
monthly and "year-to-date" financial statements for the last three (3) years;
c) A statement of current accounts receivable and accounts payable;
d) Any Documents or statements of all current loans, obligations and payables,
if any, you owe to the business and all loans, obligations or other payables
owed to you;
e) All evaluations or appraisals or any other Documents reflecting the value of
the business or the value of your interest in the business or legal entity; and
If you owned, controlled or had any interest in such business or entity within
the last three (3) years, but do not own such an interest, produce all
Documents related to the date of acquisition of your interest, the
consideration paid to acquire such interest, the date on which such interest
terminated, whether by gift, sale or otherwise, and the consideration
received therefore with respect to such business.
EXHIBIT A ~ SUBPOENA OF GARY EBBY
Sean Toddv. Christine Todd; Superior Court of Cabb County, CAFN: 23102887
Page 13 of 19
32.
All partnership agreements, operating agreements, stockholder agreements, buy-
sell agreements, stock subscriptions or any other agreements of any nature, relating to
any partnership, corporation, business venture or other business or legal entity you
own, control or in which you have an interest.
33.
Any partnership agreements, stockholder agreements, buy-sell agreements or
other agreements of any nature relating to any partnership, corporation, or other
business or legal entity in which you have an interest.
34.
Any and all checking and savings account records, and records of any money
market accounts or other investment accounts, maintained in connection with any
partnership, corporation, business, legal entity or association of which you have an
interest, for the past three (3) years.
35.
Any and all minute books of any corporation in which you have any interest.
PROPERTY INTEREST AND APPRAISALS
36.
All Documents evidencing your ownership or the status or value of any present or
future interest you have in any corporation, partnership, sole proprietorship, securities,
trust, estate, reversionary interest, partnership, joint venture, syndicate, jewelry,
furniture, art and in any other intangible, real or Personal property from January 1, 2021
until the date of final hearing or trial of this case. Documents include, but are not limited
EXHIBIT A~ SUBPOENA OF GARY EBBY
Sean Todd v. Christine Todd, Superior Court of Cobb County: CAFN: 23102887
Page 14
of 19
to, appraisals, receipts, contracts, cards, letters, notes, journals and statements. Said
request shall include, but not be limited to, any documentation relating to the sale or
trade of any personal property over $500.00.
GIFTS
37.
All Documents pertaining to or evidencing a gift of any kind from you to any
Person, entity or trust, or any Person or entity made on your behalf to any Person, entity
or trust, valued in excess of five hundred ($500.00) dollars, within the last three (3)
complete years and year to date, until the final trial in the above-styled case;
38.
All Documents reflecting any gift you received or any Person or entity received
on your behalf, valued in excess of five hundred ($500.00) dollars, from any Person,
entity or trust within the last three (3) complete years and year to date, until the final trial
in the above-styled case.
39.
All Documents reflecting any gift, irrespective of value, you or any other Person
or entity on your behalf has received or given to another Person with whom you are
having or have had a romantic relationship? from January 2021 until the date of final trial
in the above styled case.
2 “Romantic relationship” is defined as an association with another Person involving physical, sexual or emotional
intimacy.
EXHIBIT A~ SUBPOENA OF GARY EBBY
Sean Todd v. Christine Todd, Superior Court of Cobb County; CAFN: 23102887
Page
15 of 19
ONLINE ACTIVITY
40.
Any Documents or tangible evidence of your online activity on any social media
website or other personal or professional online accounts you have maintained, created
or used, including, but not limited to printouts of your walls, feeds, boards, browser
history, blogs, videos, vlogs (video blogs), pins, profiles, “statuses, “posts, tweets, chats,
private inbox messages, instant messages, online advertisements or announcements
you posted or responded to, messages and any other Documents on social networking
sites, chat rooms, internet forums, social networking within the last three (3) complete
years and year to date, until the final triat in the above-styled case. Social media
websites include, but are not limited to, facebook.com, myspace.com, linkedin.com,
twitter.com, Google+, pinterest.com, youtube.com, mylife.com, etc.
OTHER PROPERTY INTERESTS
At.
Except as already produced in response to these Requests, produce all
Documents and tangible evidence, including, but not limited to, statements of account,
deeds, notes, trust agreements, contracts, agreements, letters, memoranda, notices,
relating to any interest you may have in any property, tangible or intangible, which has
not already been produced pursuant to any other request in this Notice to Produce and
Request for Production of Documents. Such property interests shall include, but are not
limited to, interests in any of the following:
a) Any trust or estate, including but not limited to present, future, or
teversionary interests;
EXHIBIT A-~ SUBPOENA OF GARY EBBY
Sean Todd v."Christine Todd, Superior Court of Cobb County, CAFN: 23102887
Page
16 of 19 .
b) Any notes or accounts receivable;
°) Any partnerships, joint ventures, or syndicates;
qd) Any negotiable or non-negotiable instruments;
e) Any U.S. Treasury Bills or Notes;
Any royalties, copyright, or patents; and
9) Any oil, gas, or mineral interests.
SUPPORTING EVIDENCE
42.
All Documents and tangible evidence of any nature which is in the possession or
control of you or your attorney, or which is being held for you by any other Person or
entity for safe keeping, which relates in any manner to any claim, allegation or defense
you raise ‘in this litigation and which you have not othenwise already produced. Evidence
shall include, but is not limited to, notes, cards, letters, photographs, film, pictures,
computer print-outs, invoices, tapes, voice recordings and clothes.
INVESTIGATIONS
43.
All letters, invoices, canceled checks, photographs, film, tape recordings, voice
recordings, invoices and/or any other Documents or tangible evidence and information
of any nature, relating to or arising from any surveillance or investigation of the conduct,
activities, or affairs of Ms. Christine Todd, or any Person or entity relevant to this case
that you performed or were performed on your behalf. If you object to or claim that any
evidence you would otherwise produce in response to this request is privileged,
EXHIBIT A — SUBPOENA OF GARY EBB'
Sean Todd v. Christine Todd; Superior Court of Cobb County; CAFN: 23102887,
Page 17 of 19
please indicate that fact and the basis for the claim of objection or privilege and
any other information in compliance with Uniform Superior Court Rule 5.5.
44.
A copy of your passport.
45.
All documents and records of any of the following expenses that you may
incurred on behaif of the Respondent's minor children for the past three (3) years:
(a) Child care costs related to your work or employment;
(b) Private school and extraordinary educational expenses;
() Tutoring and private lessons;
d) Extracurricular activities;
(e) Summer and sports camps;
( Health insurance premium payments and extraordinary medical expenses;
and
(g) Health care expenses not covered or paid by insurance carrier (including
co-pays and deductibles).
46.
Proof of payment of life insurance premium payments that you pay on your life
for the benefit of Respondent's minor child(ren).
47.
Copies of all records of checking, savings, money market, PayPal, Venmo, Cash
App, trust accounts, offshore trust accounts, off shore bank accounts,
investment/brokerage, retirement, stocks accounts, crypto currency and/or digital
EXHIBIT A~ SUBPOENA OF GARY EBBY
Sean Todd v. Christine Todd; Superior Court of Cobb County; CAFN: 23102887
Page
18 of 19
currency maintained by you, individually and/or jointly with others, by any third party
person into which you have signature authority, can access, and/or control and/or
access, and/or for any business or corporation that you control or have controlled, for
the past three (3) years and continuing to the date of trial of the above-styled case.
including, but not limited to, monthly, quarterly, semi-annual, and annual
Preview
SUBPOENA SUMMIT COUNTY COMMON PLEAS COURT CLV. RULE 48 Sean Garnet Todd CASE NO. 2024 00 0006 PLAINTIFF 23102887 Ys. FOREIGN CASE NO. Christine Lynn Todd (if applicable) SUBPOENA IN CIVIL CASE DEFENDANT Charlotte Ruble, Esq. ATTORNEY/PRO SE: 11475 Great Oaks Way Suite 125 ADDRESS: Alnharetta GA 2nn?? 678 879 9000 Gary Ebby PHO! TO: (NAME) 1120 Nina Ln, (ADDRESS) SUPREME CT. NO. Akron, OH 44333 (CITY, STATE, ZIP) YOU ARE HEREBY COMMANDED TO ATTEND AND GIVE TESTIMONY AT A (TRIAL)(HEARING)(DEPOSITION) ON THE February 930AM 388 South Main St. Akron DATE 22, 2024 TIME:, piace; Suite 440 x PRODUCE DOCUMENTS, ELECTRONICALLY STORED INFORMATION, OR TANGIBLE THINGS AT TRIAL,HEARING OR DESPOSITION. > _ PRODUCE AND PERMIT INSPECTION AND COPYING OF ANY DESIGNATED DOCUMENTS OR ELECTRONICALLY STORED INFORMATION THAT ARE IN YOUR POSSESSION, CUSTODY, OR CONTROL. > PRODUCE AND PERMIT INSPECTION AND COPYING, TESTING, OR SAMPLING OF ANY TANGIBLE THING THAT ARE IN YOUR POSSESSION, CUSTODY, OR CONTROL. 2X PERMIT ENTRY UPON DESIGNATED LAND OR OTHER PROPERTY THAT IS IN THE POSSESSION OR CONTROL OF YOU FOR THE PURPOSES DESCRIBED IN CIV. R. 34(A)(3). See ExhibitA enclosed. DESCRIPTION OF ITEMS TO BE PRODUCED: . HEREOF FAIL NOT UNDER PENALTY OF THE LAW WITNESS MY SIGNATURE AND SEAL OF SAID COURT, THIS week we TAVIA GALONSKI ° Seow OF: LEV ve a7. ) 20, . Check, ger Ne2 olay ~ SUMMIT COUNTY CLERK OF COURTS : wr ox DeputYeRik * RETURN OF SERVICE. Isis -4 Received this Subpoena on the day of 20__at M. and oa the day of. 20_,at M.,, I served the same upon by delivering to. Personally or Residential a true copy of this subpoena. Sheriff-Attorney-Process Server-Notary Mileage: miles@ ; TOTALS PROTECTION OF PERSONS SUBJECT TO SUBPOENAS: L A party or an attomey responsible for the issuance and service of a subpoena sliall take reasonable steps to avoid imposing undue burden or expense on a person subject to that subpoena. 2. {a)A person commanded to produce under divisions (A)(1)(0)(i), (ii), (iv) oF (v) ofthis rule need not appearin person at the place of prod ion or inspection unless commanded to attend and give testimony at a deposition, he: or trial, (b) Subject to division (D)(2) of this rule, a person commanded to produce under divisions (AX1)(b)(i) li) iv), or (v) of this rule may, within fourteen days after service of tlie subpoena or before the time specified for compliance if such time is less than fourteen days after service, serve upon the party or attorney designated in the subpoena written objectioas to production. If objection is made, the party serving the subpoena shall not be entitled to production except pursuant to an order of the court by which the subpoena was issued. If objectionhas been made, the party sexving the subpoena, upon notice to the person commanded to produce may move at any time for an orderto compel the production, An order to compel production shall protect any person who is not a party or an officer of a party from significant expense resulting from the production commanded. 3.0n timely motion, the court from which the subpoena was issued shall quash or inodify the subpoena, or order appearance or production only under specified conditions, if the subpoena does any of the following — Fails to allow reasonable time to comply; requires disclosure of privileged or otherwise protected matter and no exception or waiver applies; requires disclosure of a fact known oropinion held by an expert not retained or specially employed by aay party in anticipation of litigation or preparation for trial as desctibed by CIV R. 26(B)(4), if the fact or opinion does not describe specific events or occurrences in dispute and results from study by the expert that was not made at request of any patty; subjects a person to undue burden. 4. Before filing a motion pursuant to division (C) (3) (d) of this rele, a person resisting discovery under this rute shall attempt to resolve any claim of undue burden through discussions with the issuing attomey. A motion filed pursuant to division (C) 3)(d) ofthis rule shall be supported by an affidavit ofthe subpoenaed person or a certificate of that person's attorney of the efforts made to resolve any claim of undue burden. 5. If amotion is made under divisiom(C}(3Y(c) or (C\3)(A) of this rule, the court shall quash or modify the subpacaa unless the party in whose behalf the subpoena is issued shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship and assures that the person to whom the subpoena is addressed will be reasonably compensated. DUTIES IN RESPONDING TO SUBPOENAS: 1. A person responding to a subpoena to produce documents shall, at the person's option, produce them as they are kept in the usual course of business or organized and labeled to correspond with the categories in the subpoena. A person producing documents or electronically stored information pursuant to a subpocna for them shall permit their inspection and copying by all parties present at the time and place set in the subpoena for inspection and copying. 2 Ifa request does not specify the form or forms for producing electronically stored information, a person responding to a subpoena may produce the information in a form or forms in which the information responding is ordinarily maintained if that form is reasonable useable, or in any form thal is reasonably useable, Unless ordered by the court or agreed to by the person subpoenaed, a person responding to a subpoena need not produce the same electronically stored information in more than one form. ‘A person need not provide discovery of electronically stored information when the production imposes undue burden or expense. On motion to compel discoveryor for a protective order, the person from whom electroaically stored information is sought must show that the informationis not reasonably accessible because of undue burden or expense. Ifa showing of undue burden or expense is made, the court may nonetheless order production of electronically stored information ifthe requesting patty shows good cause. The court shall consider the factors in Civ. R. 26(8)(4) when determining if good cause exists, In ordering production of electronically stored information, the court may specify the format, extent, timing, allocation of expenses and other conditions for discovery of the electronically stored infonnation. When information subject to a subpoena is withheld on a claim that it is priviteged or subject to protection as trial preparation materials, the claim shall be made expressly and shall be supported by a description of the nature of the documents, communications, or things not produced that is sufficient to enable the demanding party to contest the claim, 5. Ifinformation is produced in response to a subpoena that is subject to a claim af privilege or of protection as trial- preparation material, the person making the claim may notify any party that recelved the information of the claim and ‘the basis for it. After being notified, a receiving party must promptly return, sequester, or destroy the specified information and any copies within the party's possession, custody or control. A party may not use or disclose the information until the claim is resolved. A receiving party may promptly present the information to the court under seal for determination of the claim of privilege or of protection as trial-preparation material. If the receiving party disclosed the information before being notified, it must take reasonable steps to retrieve it. The person who produced the information must preserve the information until the claim is resolved, SANCTIONS: AL, Failure by any person without adequate excuse to obey a subpoena served upon that person may be deemed contempt of the court from which the subpoena issued. “A subpoenaed person or that person's attomey who fiivolously resists discovery under this rule may be required by the court to pay the reasonable expenses, including reasonable attorney's fees ofthe party seeking discovery. The court from which a subpoena was issued may impose upon a party or attomey in breach of the duty imposed by division (C)(4) of this rule an appropriate sanction, which may includa, but is not limited to, lost eamings and reasonable attomey's fees. 2024 00 0006 IN THE SUPERIOR COURT OF COBB COUNTY STATE OF GEORGIA SEAN GARNET TODD, PLAINTIFF, CIVIL ACTION FILE NO. 23102887 vs. CHRISTINE LYNN TODD, DEFENDANT. \ EXHIBIT A - SUBPOENA OF GARY EBBY DEFINITIONS As used herein, the terms listed below are defined as follows: 1. A “Document” includes, by way of illustration, but not by way of limitation, the following items which are within the possession, custody or control of the Mr. Gary Ebby or his agents, employees, servants, officers, representatives, attorneys, and any other Person acting on his behalf, whether individually or collectively, who have obtained, or who ‘are ina position to obtain, information for or on behalf of the Mr. Gary Ebby, including both copies -and originals, unless otherwise stated: letters; reports; agreements; communications; internal company communications; original or Preliminary notes; correspondence; telegrams; radiograms; telex messages; memoranda; summaries or records of telephone conversations; routing slips or memoranda; calls or service reports; audibly reproducible recording on tape, disc or the like; computer printouts; microfilm; microfiche; summaries or records of Personal interviews and conversations; diaries; forecasts; statistical statements; graphs; drawings; positive and negative prints of pictures, motion or still, including excised frames of motion pictures; minutes or records of conferences and meetings, :XHIBIT A — SUBPOENA OF GARY EBB" Sean Toddv. Christine Todd, Superior Court of Cobb County; CAFN: 23102887 Page 1 of 19 including meeting of directors, executive committees, financial committees; financial statements; lists of Persons attending meetings or conferences; expression or statements of policy; reports or summaries of interviews; reports or summaries of investigations; opinions or reports of consultants and/or investigators; patent, trademark or copyright searches; opinions of counsel records or summaries of negotiations; contracts or agreements; brochures; pamphlets; catalogs; advertisements; circulars; trade letters; press or publicity releases; drafts of any Documents; revisions or drafts of any Documents; stenographic or graphic material in whatever form, including drafts and reproductions. For purposes of this request, any Document bearing on any sheet or side thereof any marks such as initials, stamped indicia, comment or notation, of any character and not part of the original Document or photographic reproduction thereof, every copy of such writing or record with the originals not in Mr. Gary's possession, custody or control; and every copy of every such writing or records where such copy is not an identical copy of an original or where such copy contains any commentary or notation whatsoever, which does not appear in the original, is to be considered and identified as a separate Document. 2. “Income” or "Gross Income" is defined per O.C.G.A. §19-6-15 (f).! 3. “Person” means any individual, firm, company, corporation, partnership, proprietorship, joint venture, association, governmental agency, organization, group 1 The definition of “Income” under 0.C.G.A. §19-6-15(f) is broader than “Income” as defined by state and federal tax laws. XHIBIT A ~ SUBPOENA OF GARY EBBY Sean Todd v. Christine Todd Superior Court of Cobb County; CAFN: 23102887 Page 2 of 19 of Persons, or any other entity. When asked to identify a "Person" who is any "individual" in an official position with a "firm, company, corporation, partnership, proprietorship, joint venture, association, governmental agency, organization, group of Persons, or any other entity," you should identify both the "individual" and that Person's relationship with the “firm, company, corporation, partnership, proprietorship, joint venture, association, governmental agency, organization, group of Persons, or any other entity.” “You,” and “Your,” refers to Mr. Gary Ebby, and his agents, employees, servants, officers, representatives, attorneys, and any other Person acting on his behalf, whether individually or collectively, who have obtained, or who are in a position to obtain, information for or on behalf of the Mr. Gary Ebby. “Petitioner” refers to Mr. Todd Sean, the Petitioner in this action. “Respondent” refers to Ms. Christine Todd, the Respondent in this action. “Answer” means the defensive pleading filed by the Respondent to the Petitioner's Complaint for Divorce, as it may be amended hereafter. Terms in the singular shall be deemed to include the plural and vice versa. Terms importing the masculine gender may be applied to females or organizations. DOCUMENTS TO BE PRODUCED EVIDENCE OF INCOME EXHIBIT A — SUBPOENA OF GARY EBBY Sean Todd v. Christine Todd, Superiar Court of Cobb County; CAFN: 23102887 Page 3 of 19 1 All pay stubs, statement of earnings, W-2 forms, 1099 forms, K-1 forms, and any other Documents evidencing any Income or funds you earned or received, directly or indirectly, whether from employment, distributions, gifts, loans or otherwise, within the last three (3) complete years and year to date, until the final trial in the above-styled case. Documents shall include, but are not limited to, financial statements, bank statements, statements of accounts receivable and payable, and other evidence of Income from business operations, work as an independent contractor’or consultant, sales of goods and services, and rental properties, less ordinary and Teasonable expenses necessary to produce self-employment Income, loan documents, including but not limited to Promissory Notes or other writings, and any documents reflecting receipt of gift funds. 2. Evidence of all self-employment income for the past three (3) years. This shall include, but not be limited to, financial statements, bank statements, statements of accounts receivable and payable, and other. documents relating to income from business operations, work as an independent contractor or consultant, sales of goods and services, and rental properties. 3 If you earn or have earned self-employment income at any time during the past three (3) full calendar years, please produce any and all evidence of your ordinary and reasonable business expenses necessary to produce such self-employment income. EXHIBIT A — SUBPOENA OF GARY EBBY Sean Todd v. Christine Todd, Superiar Court of Cobb County; CAFN: 23102887 Page 4 of 19 . TAXES 4 All Income tax returns that you filed or that have been filed on your behalf, whether individually and/or jointly with any other Person or entity, with any federal or state government in the past three (3) years and all succeeding years during the pendency of the above-styled case. Your Tesponse should include all schedules, worksheets, W-2, 1099, K-1s from any partnerships, Sub-S corporations or trusts, and any other Documents prepared by you, your accountant, or provided to you by your employer or any other Person or entity, pertaining to the taxable years requested. If the filing date of any return has been extended or you are otherwise late in your required filing, identify each return and explain why said return has not been filed. 5 If any state or federal Income tax returns for the last three (3) years have not been prepared or filed, please produce all copies of any tax source Documents (i.e.: W- 2, 1099 and K-1} you have received or prepared on your behalf. 6 All Documents, including, but not limited to, notices, statements and/or bills, reflecting any taxes paid or owed, or unpaid but owing and any liens by any taxing authority on any business or property, tangible or intangible, you control, own, or in which you have any interest or equity in that you have received within the last three (3) complete years and year to date, until the final trial in the above-styled case. EXHIBIT A — SUBPOENA OF GARY EBBY Sean Toddv. Christine Todd, Superior Court of Cobb County; CAFN: 23102887 Page 5 of 19 7. All declarations of estimated income tax filed by you or on your behalf with the Internal Revenue Service for the past three (3) years. FRINGE BENEFITS 8 All Documents and records evidencing any fringe benefits available to you from any business or entity in which you are an employee or in which you have any legal or equitable ownership interest, including, but not limited to, auto expense, travel expense, telephone, Personal living and entertainment expense such as meal reimbursement or per diem, bonuses, health, accident, dental and hospital insurance. EXPENSE REIMBURSEMENT 9. All Documents, receipts and vouchers reflecting funds you received or to which you are entitled to receive, directly or indirectly, for reimbursement or payment of expenses, from yourself (if self-employed), your employer or any other Person or entity within the last three (3) complete years and year to date, until the final trial in the above- styled case. - SOCIAL SECURITY STATEMENT 10. A copy of your Social Security Earnings statement for the last calendar year. EXHIBIT A~ SUBPOENA OF GARY EBB’ Sean Todd v. Chnsine Tod SI juperior Court of Cobb County; CAFN: 23102887 Page 6 of OTHER INCOME 11. All Documents and records of social security payments, disability payments, and retirement benefits to which you have received or are entitled to receive for yourself or a dependent within the last three (3) complete years and year to‘date, until the final trial in the above-styled case. Provide statements, notifications, award letters, your most recent annual statement and any other Documents relating to your current or future retirement or disability benefits from any Person, entity and/or the Social Security Administration. CREDIT CARDS 12. Produce all statements, receipts and all other Documents evidencing charges incurred, payments made and the balance due on all unsecured debt, including but not limited to any credit cards, credit lines and charge accounts, whether the account is open or closed, that are or have been maintained in your name individually ‘or jointly with any other Person or entity, including Ms. Christine Todd, or for which you are or were an authorized signatory within the last three (3) complete years and year to date, until the final trial.in the above-styled case. ACCOUNTS 13. All records of bank checking accounts, savings accounts, cash management accounts, certificates of deposit, investment and money market accounts maintained by you, individually and/or jointly with others, or maintained by you as trustee or custodian EXHIBIT A — SUBPOENA OF GARY EBBY Sean Tadd v. Christine Todd; Superior Court of Cobb County; CAFN: 23102887 Page 7 of 19 for any other person or persons, including but not limited to monthly bank statements, cancelled checks, deposit slips, check registers, passbooks, statements relating to savings accounts, certificates of deposit, and any other such records for the past three (3) years and continuing to the date of trial of the above-styled case. . 14. All copies of personal financial and net worth statements submitted by you, individually and/or jointly with any other person or persons, to any bank or lending institution for the past three (3) years. 15. Any and all applications for credit, bank accounts, loans or other financial products of any nature whatsoever which you have submitted to any person or institution for the past three (3) years. 16. Any and all notes, installment obligations, lines of credit, home equity loans, and other obligations of any nature whatsoever of which you are currently an obligor, individually and/or jointly with any other person or persons. If there are monthly statements or check registers relating to any loan account, please produce these records for the past three (3) years. 17. Any and all notes or obligations of any nature whatsoever of which you are currently an obligee, individually and/or jointly with any other person or persons. EXHIBIT A - SUBPOENA OF GARY EBBY Seari Tedd v. Christine Todd, Superior Court of Cobb County; CAFN: 23102887 Page 8 of 19 18. Any and all notes, installment obligations, or other obligations with a principal amount of $1,000 or more (excluding charge account or credit cards) of which you were an obligor, individually and/or jointly with any other person or persons in the past three (3) years,or any time thereafter, but of which you are no longer an obligor or joint obligor. 19. ‘ Any and all monthly credit and charge statements and receipts showing all charges and payments made and the balance due on any credit cards or charge accounts maintained by you or regularly used by you, including but not limited to, any accounts maintained in your name or yourself together with other person or entity, for the past three (3) years. 20. All partnership tax returns and corporate tax returns filed with the Federal and State governments for any partnership, corporation, or association of which you were a partner or stockholder for the past three (3) years. 21. Any and all monthly, quarterly, or annuai cash flow summaries, profit or loss statements, or income statements of any nature for any partnership, corporation, or association of which you are a partner or a stockholder for the past three (3) years. EXHIBIT A —- SUBPOENA OF GARY EBBY Sean Toddv. Christine Todd, Superior Court of Cobb County; CAFN: 23102887 Page 9 of 19 22. Any and all balance sheets or statements of assets and liabilities for any partnership, corporation, or association of which you are a partner or a stockholder for the past three (3) years. 23. Any partnership agreements, stockholder agreements, buy-sell agreements or other agreements. of any nature relating to any partnership, corporation, or other business entity in which you have an interest. 24. Any and all checking and savings account records, and records of any money market accounts or other investment accounts, maintained in connection with any partnership, corporation, or association of which you are a partner or a stockholder, for the past three (3) years. 25. Any and all minute books of any corporation in which you have any interest. INVESTMENTS AND OTHER SECURITIES 26. Ali Documents evidencing control, ownership or interest ih any securities, stocks, stock options or grants, investments, mutual funds, liquid asset funds held personally or through any entity (foreign or domestic), whether held individually or jointly with any other Person or entity, within the last three (3) complete years and year to date, until the final trial in the above-styled case. Documents include, but are not limited to, certificates, statements, tax source Documents, notices and disclosures. EXHIBIT A~ SUBPOENA OF GARY EBBY Sean Todd v. Christine Todd, Superior Court of Cobb County; CAFN: 23102887 Page 10 of 19 RETIREMENT 27. All Documents, records, statements and any other tangible evidence relating to any interest you have or had in any retirement plans, including but not limited to annuities, profit sharing plans, pension plans, savings plans, thrift saving plans, Keogh plans, Individual Retirement Accounts, 401(k) plans, 401(a) plans, 403(b) plans, cash or deferred compensation plans or any other retirement accounts or plans of any nature whatsoever in which you have an interest, whether or not any such plan is qualified pursuant to the Internal Revenue Code of 1954, as amended, or unqualified within the last three @) complete years and year to date, until the final trial in the above-styled case. NET WORTH STATEMENTS AND CREDIT APPLICATIONS 28. All financial net worth statements and credit applications you, some other Person or entity on your behalf or any entity in which you have any interest or control prepared or submitted to any bank, lending institution or to any Person or entity, from January 2021 until the date of final trial in the above-styled case. LIABILITIES 29. All notes, installment obligations, lines of credit, home equity loans, and any other Documents or evidence, including, but not limited to, monthly statements, check tegisters, loan payment books, coupon books, reflecting any obligation, of any nature whatsoever, for which you are or were obligated in any manner, whether individually EXHIBIT A - SUBPOENA OF GARY EBBY Sean Todd v. Christine Todd; Superior Court of Cobb County; CAFN: 23102887 Page11 of 19 and/or jointly with any other Person or entity within the last three (3) complete years and year to date, until the final trial in the above-styled case. REAL PROPERTY 30. Please produce the following Documents from January 1, 2021 onward until the date of final hearing or trial of this case: a) Any and all Documents, memoranda, closing statements or writings evidencing any interest you have, had or may acquire in real property, whether as owner, co- owner, fiduciary, trust beneficiary (vested or contingent), partner, limited partner, shareholder, joint venturer, mortgagee, developer, manager of otherwise. This request includes but is not limited to any Wills, Trusts, Deeds, Settlement Statements (also known as a HUD-1 statement), any closing documents, or any other documents evidencing your acquisition or interest in the property; b) Copies of all Documents reflecting real estate mortgages held by you or by any trust, business or entity in which you have or had a present or contingent interest; ¢) Any evidence showing all contributions in cash or otherwise made by you, Ms. Christine Todd, a Third person, or any entity you own or in which you have an interest in to the acquisition any real property or mortgages identified in subsection (a) and (b) above; and qd) All Documents pertaining to real estate leases (including lease purchase agreements), whether you or any entity in which you own, control or in which you have an interest in are listed as lessor or lessee. EXHIBIT A — SUBPOENA OF GARY EBBY Sean Todd v. Christine Todd, Superior Court of Cobb County; CAFN: 23102887 Page 12 of 19 BUSINESS INTERESTS 31. With respect to any firm, trust entity, partnership, limited partnership, company, corporation, venture, sole proprietorship or any other business or legal entity of any “kind, in which you own, control, have a financial interest in or from which you receive or will be receiving any Income or compensation, produce the following Documents: a) Complete federal, state and any other government tax returns (including any source Documents, schedules, exhibits and forms) of any kind that have been prepared and/or filed for the last three (3) years; b) Annual balance sheets and profit and loss statements and quarterly, monthly and "year-to-date" financial statements for the last three (3) years; c) A statement of current accounts receivable and accounts payable; d) Any Documents or statements of all current loans, obligations and payables, if any, you owe to the business and all loans, obligations or other payables owed to you; e) All evaluations or appraisals or any other Documents reflecting the value of the business or the value of your interest in the business or legal entity; and If you owned, controlled or had any interest in such business or entity within the last three (3) years, but do not own such an interest, produce all Documents related to the date of acquisition of your interest, the consideration paid to acquire such interest, the date on which such interest terminated, whether by gift, sale or otherwise, and the consideration received therefore with respect to such business. EXHIBIT A ~ SUBPOENA OF GARY EBBY Sean Toddv. Christine Todd; Superior Court of Cabb County, CAFN: 23102887 Page 13 of 19 32. All partnership agreements, operating agreements, stockholder agreements, buy- sell agreements, stock subscriptions or any other agreements of any nature, relating to any partnership, corporation, business venture or other business or legal entity you own, control or in which you have an interest. 33. Any partnership agreements, stockholder agreements, buy-sell agreements or other agreements of any nature relating to any partnership, corporation, or other business or legal entity in which you have an interest. 34. Any and all checking and savings account records, and records of any money market accounts or other investment accounts, maintained in connection with any partnership, corporation, business, legal entity or association of which you have an interest, for the past three (3) years. 35. Any and all minute books of any corporation in which you have any interest. PROPERTY INTEREST AND APPRAISALS 36. All Documents evidencing your ownership or the status or value of any present or future interest you have in any corporation, partnership, sole proprietorship, securities, trust, estate, reversionary interest, partnership, joint venture, syndicate, jewelry, furniture, art and in any other intangible, real or Personal property from January 1, 2021 until the date of final hearing or trial of this case. Documents include, but are not limited EXHIBIT A~ SUBPOENA OF GARY EBBY Sean Todd v. Christine Todd, Superior Court of Cobb County: CAFN: 23102887 Page 14 of 19 to, appraisals, receipts, contracts, cards, letters, notes, journals and statements. Said request shall include, but not be limited to, any documentation relating to the sale or trade of any personal property over $500.00. GIFTS 37. All Documents pertaining to or evidencing a gift of any kind from you to any Person, entity or trust, or any Person or entity made on your behalf to any Person, entity or trust, valued in excess of five hundred ($500.00) dollars, within the last three (3) complete years and year to date, until the final trial in the above-styled case; 38. All Documents reflecting any gift you received or any Person or entity received on your behalf, valued in excess of five hundred ($500.00) dollars, from any Person, entity or trust within the last three (3) complete years and year to date, until the final trial in the above-styled case. 39. All Documents reflecting any gift, irrespective of value, you or any other Person or entity on your behalf has received or given to another Person with whom you are having or have had a romantic relationship? from January 2021 until the date of final trial in the above styled case. 2 “Romantic relationship” is defined as an association with another Person involving physical, sexual or emotional intimacy. EXHIBIT A~ SUBPOENA OF GARY EBBY Sean Todd v. Christine Todd, Superior Court of Cobb County; CAFN: 23102887 Page 15 of 19 ONLINE ACTIVITY 40. Any Documents or tangible evidence of your online activity on any social media website or other personal or professional online accounts you have maintained, created or used, including, but not limited to printouts of your walls, feeds, boards, browser history, blogs, videos, vlogs (video blogs), pins, profiles, “statuses, “posts, tweets, chats, private inbox messages, instant messages, online advertisements or announcements you posted or responded to, messages and any other Documents on social networking sites, chat rooms, internet forums, social networking within the last three (3) complete years and year to date, until the final triat in the above-styled case. Social media websites include, but are not limited to, facebook.com, myspace.com, linkedin.com, twitter.com, Google+, pinterest.com, youtube.com, mylife.com, etc. OTHER PROPERTY INTERESTS At. Except as already produced in response to these Requests, produce all Documents and tangible evidence, including, but not limited to, statements of account, deeds, notes, trust agreements, contracts, agreements, letters, memoranda, notices, relating to any interest you may have in any property, tangible or intangible, which has not already been produced pursuant to any other request in this Notice to Produce and Request for Production of Documents. Such property interests shall include, but are not limited to, interests in any of the following: a) Any trust or estate, including but not limited to present, future, or teversionary interests; EXHIBIT A-~ SUBPOENA OF GARY EBBY Sean Todd v."Christine Todd, Superior Court of Cobb County, CAFN: 23102887 Page 16 of 19 . b) Any notes or accounts receivable; °) Any partnerships, joint ventures, or syndicates; qd) Any negotiable or non-negotiable instruments; e) Any U.S. Treasury Bills or Notes; Any royalties, copyright, or patents; and 9) Any oil, gas, or mineral interests. SUPPORTING EVIDENCE 42. All Documents and tangible evidence of any nature which is in the possession or control of you or your attorney, or which is being held for you by any other Person or entity for safe keeping, which relates in any manner to any claim, allegation or defense you raise ‘in this litigation and which you have not othenwise already produced. Evidence shall include, but is not limited to, notes, cards, letters, photographs, film, pictures, computer print-outs, invoices, tapes, voice recordings and clothes. INVESTIGATIONS 43. All letters, invoices, canceled checks, photographs, film, tape recordings, voice recordings, invoices and/or any other Documents or tangible evidence and information of any nature, relating to or arising from any surveillance or investigation of the conduct, activities, or affairs of Ms. Christine Todd, or any Person or entity relevant to this case that you performed or were performed on your behalf. If you object to or claim that any evidence you would otherwise produce in response to this request is privileged, EXHIBIT A — SUBPOENA OF GARY EBB' Sean Todd v. Christine Todd; Superior Court of Cobb County; CAFN: 23102887, Page 17 of 19 please indicate that fact and the basis for the claim of objection or privilege and any other information in compliance with Uniform Superior Court Rule 5.5. 44. A copy of your passport. 45. All documents and records of any of the following expenses that you may incurred on behaif of the Respondent's minor children for the past three (3) years: (a) Child care costs related to your work or employment; (b) Private school and extraordinary educational expenses; () Tutoring and private lessons; d) Extracurricular activities; (e) Summer and sports camps; ( Health insurance premium payments and extraordinary medical expenses; and (g) Health care expenses not covered or paid by insurance carrier (including co-pays and deductibles). 46. Proof of payment of life insurance premium payments that you pay on your life for the benefit of Respondent's minor child(ren). 47. Copies of all records of checking, savings, money market, PayPal, Venmo, Cash App, trust accounts, offshore trust accounts, off shore bank accounts, investment/brokerage, retirement, stocks accounts, crypto currency and/or digital EXHIBIT A~ SUBPOENA OF GARY EBBY Sean Todd v. Christine Todd; Superior Court of Cobb County; CAFN: 23102887 Page 18 of 19 currency maintained by you, individually and/or jointly with others, by any third party person into which you have signature authority, can access, and/or control and/or access, and/or for any business or corporation that you control or have controlled, for the past three (3) years and continuing to the date of trial of the above-styled case. including, but not limited to, monthly, quarterly, semi-annual, and annual