[Proposed] ORDER RE DOCUMENT PRODUCTION AND CONTINUED JUDGMENT DEBTOR EXAM

LAUREL BEELER, Magistrate Judge.

On July 22, 2014, the Judgment Debtor Bridges Tire and Wheel Service, Inc. appeared through Timothy Bridges, its person designated most knowledgeable of the corporate property and debts, in Courtroom C of the above-entitled Court located at 450 Golden Gate Avenue, 15th Floor, San Francisco, CA, for the Debtor Exam as ordered by the Court (Dkt. 16). Because Judgment Debtor failed to produce at the Exam documents as subpoenaed by Plaintiffs, Plaintiffs agreed to a continuance of the Debtor Exam. Accordingly, IT IS HEREBY ORDERED as follows:

(1) Judgment Debtor shall appear for the continued Judgment Debtor Exam on Tuesday, September 30, 2014 at 9:00 a.m in Courtroom C of the above-entitled Court located at 450 Golden Gate Avenue, 15th Floor, San Francisco, CA.

(2) Judgment Debtor shall produce all documents in its possession as requested in the Civil Subpoena (Duces Tecum) for Personal Appearance and Production of Documents and Things at Trial or Hearing and Declaration and attachment thereto dated June 3, 2014 ("Subpoena"). The Subpoena was personally served on Timothy Bridges on June 9, 2014. (Dkt. 17). Timothy Bridges shall hand deliver, or cause to be hand delivered, all documents responsive to the Subpoena to Saltzman & Johnson Law Corporation, 44 Montgomery Street, Suite 44, San Francisco, CA 94104, by 5:00 pm on Friday, August 29, 2014. Attached hereto as "Exhibit A" is a true and correct copy of said Subpoena.

IT IS SO ORDERED.

EXHIBIT

AUTOMOTIVE INDUSTRIES PENSION TRUST FUND, et al. vs. BRIDGES TIRE AND WHEEL SERVICE, INC., a California corporation

U.S.D.C., Northern District of California, Case No. CV 11-4538 LB

ATTACHMENT 2

TO SUBPOENA DUCES TECUM

TO CIVIL SUBPOENA (DUCES TECUM) FOR PERSONAL APPEARANCE AND PRODUCTION OF DOCUMENTS

Bridges Tire and Wheel Service, Inc., through its designated person most knowledgeable of corporate property and debts, will be questioned regarding all information necessary in any way to aid in the recovery of the Judgment entered in the instant action, including but not limited to, the following:

DEFINITIONS

1. "Communication(s)" as used herein shall mean, without limitation, any transfer of information, written, oral, or by any means, or any record or recording of any such transfer.

2. "Person(s)" as used herein shall mean, without limitation, a natural person, corporation, limited liability company, partnership, trust, association, joint venture, firm, tenancy-in-common, or other business enterprise or legal entity and includes both the singular and plural.

3. Each of the words "discussing," "reflecting," "concerning," "pertaining," "relating," "involving," "evidencing," or "referring" shall be defined to include the common meanings of all those terms, and shall include indirect as well as direct references to the subject matter set forth herein.

5. "Business(es)" as used herein shall mean, without limitation, corporation, limited liability company, partnership, sole proprietorship, trust, estate, association, joint venture, firm, tenancy-in-common, or other business enterprise or legal entity and includes both the singular and plural.

6. The terms "identify" and "describe:"

(a) When used with reference to a natural person, shall mean, without limitation, to state the person's full name (including current and all former names), present or last known address, present or last known position or business affiliation, position or business affiliation at the time in question, and a general description of the business in which the person is engaged.

(b) When used with reference to a corporation, partnership, association, joint venture, firm or other enterprise or entity other than a natural person, shall mean, without limitation, to state its full name and/or trade name, address, organization form, and a brief description of the functions and activities in which such entity is engaged.

7. In addition to definitions otherwise applicable, the following definitions also apply to these requests:

(a) Any reference to a party shall include, where applicable, its corporate parents, subsidiaries, predecessors and affiliates, and its and their officers, directors, agents and employees.

(b) "Bridges Tire" shall mean Defendant and Judgment Debtor, Bridges Tire and Wheel Service, Inc., a California corporation.

REQUESTS

1. Identification by entity name and all dbas of all shareholders of Bridges Tire. Provide copies of all stock certificates, stock registries, membership certificates, and/or operating agreements. Shareholders include without limitation:

2. Identification by entity name and all dbas of all trades or businesses and all real property, in which Bridges Tire has an interest. Provide copies of all stock certificates, stock registries, membership certificates, operating agreements, and/or deeds of trust.

3. Title documents to all equipment and vehicles of Bridges Tire.

4. Title documents to all equipment and vehicles of any and all trades or businesses identified in response to Request No. 2, above.

5. All purchase orders, change orders, accepted bids and contracts which relate in any way to work performed by the Bridges Tire from November 1, 2013 to the present.

6. All purchase orders, change orders, accepted bids and contracts which relate in any way to work performed by any and all trades or businesses identified in response to Request No. 2, above, from November 1, 2013 to the present.

7. Bridges Tire's federal and state income tax returns, including all supporting schedules, statements, forms and attachments filed therewith (e.g. Form 8594, Asset Acquisition Statement) for the years 2011 to the present.

8. All federal and state income tax returns, including all supporting schedules, statements, forms and attachments filed therewith (e.g. Form 8594, Asset Acquisition Statement) for the years 2011 to the present, for any and all trades or businesses identified in response to Request No. 2, above.

9. Bridges Tire's annual financial statements, both audited and unaudited, prepared on or after January 1, 2012.

10. Annual financial statements, both audited and unaudited, of any and all trades or businesses identified in response to Request No. 2, above, prepared on or after January 1, 2012. .

11. Bridges Tire's monthly financial statements, both audited and unaudited, prepared on or after January 1, 2013.

12. Monthly financial statements, both audited and unaudited, of any and all trades or businesses identified in response to Request No. 2, above, prepared on or after January 1, 2013.

13. All bank statements, deposit slips and canceled checks for all accounts held by Bridges Tire for the period November 1, 2013 to the present.

14. All bank statements, deposit slips and canceled checks for all accounts held by any and all trades or businesses identified in response to Request No. 2, above, for the period November 1, 2013 to the present.

15. All accounts receivable lists generated by Bridges Tire since November 1, 2013 to the present.

16. All accounts receivable lists generated by any and all trades or businesses identified in response to Request No. 2, above, since November 1, 2013 to the present.

17. All accounts payable lists generated by Bridges Tire since November 1, 2013 to the present.

18. All accounts payable lists generated by any and all trades or businesses identified in response to Request No. 2, above, since November 1, 2013 to the present.

19. All accounts payable lists generated by any and all trades or businesses identified in response to Request No. 2, above, since November 1, 2013 to the present.

20. All cash disbursement journals for Bridges Tire since January 1, 2012 to the present.

21. All cash disbursement journals for any and all trades or businesses identified in response to Request No. 2, above, since January 1, 2012 to the present.

22. All notes or loans made by Bridges Tire to any of its shareholders identified in response to Request No. 1, above, at any time during the years 2012 to the present.