To: 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 02/22 INDEPENDENCE COUNTY, ARKANSAS ‘ORCUTT CLERK GREG WALLIS. FILED FOR RECORD BY CARMEN DUNCAN D.C. DATE: DECEMBER 18, 2019 TIME: 09:05:02 INTHE CIRCUIT COURT OF INDEPENDENCE COUNTY, ARKANSAS LUNDEN ALEXIS ROBERTS PLAINTIFF ed Case No: 32DR-19-187 ROBERT HUNTER BIDEN DEFENDANT I 2D DIV. | MOTION TO COMPEL DISCOVERY COMES NOW the plaintiff, by and through her attorneys, LANCASTER & LANCASTER LAW FIRM, PLLC, and for her motion states: 1. That the plaintiff propounded interrogatories and requests for » production of documents on August 21, 2019. See exhibit one (attached). 2. That the defendant objected to answering any of the discovery questions. 3. ‘That the plaintiff made a good faith effort to resolve this discovery dispute, even agreeing to voluntarily stay discovery. See exhibit two (attached). 4. That, after service and personal jurisdiction were resolved and a temporary hearing held, the plaintiff made a second good faith attempt to resolve the discovery dispute. See exhibit three (attached). Pleading further, this was after the Court granted Mr. Biden's motion for a protective order on December 2, 2019, even though he did not personally appear, his attorneys had been relieved, and was an absent, pro se litigant. ORIGINAL AieGASTER LAN FOTo: 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 03/22 5. That, again, the defendant has failed to answer reasonable discovery requests necessary to swiftly and fairly adjudicate this case. See exhibit four (attached). 6. That these objections to written discovery come after the defendant moved to quash a deposition and his argument to the Court during a conference call supporting his motion to quash was that “written discovery was outstanding and not yet answered.” 7. That it should, by now, be abundantly clear to the Court that the defendant is not going tdSovide any of his discoverable financial information unless the Court forces him to do so. 8 That the defendant has provided no support for this child for over a year. ‘The Court should not let the deféndant continue to avoid his natural and legal duty to support his child by failing to provide basic information about his income, finances, and lifestyle 9. That this Court should compel the defendant to answer the interrogatories and requests for production documents in time for the January 7, 2020, hearing in this case. 10. That this Court should order the defendant to pay the plaintiff's attorney's fees and costs. WHEREFORE the plaintiff moves this honorable Court for an order compelling the defendant to answer basic discovery questions for attorney's fees andTor 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 04/22 costs: and for all other just and proper relief to which she might be entitled. Respectfully Submitted, LANCASTER & LANCASTER LAW FIRM, PLLC P.O. Box 1295 ORIGINAL Benton, Arkansas 72018 iveasren an nat P: (501) 776-2224 F: (501) 778-6186 By: . Lancaster, 2011179 CERTIFICATE OF SERVICE certify that a copy of the foregoing has been delivered by the below method to the following person or persons: First Class Mail Pane Nf) Email AOC/ECF Hand Delivery Brent Langdon blangdon@ldatty.com on this !8__ DAY of DECEMBER, 2019. Clintofi W. LancasterTor 18707938868 Prom: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 05/22 2! Lancaster & Lancaster Law Firm, piic seoow-ThelancasterLawFirm.cnmn ROBERTS vy. BIDEN MOTION TO COMPEL DISCOVERY EXHIBIT NO. 1. FIRST AND LAST PAGE OF INTERROGATORIES PROPOUNDED ON AUGUST 21, 2019Tor 18707938888 From: 15017786186 Date: 12/18/19 Time: 51 AM Page: 06/22 IN THE CIRCUIT COURT OF INDEPENDENCE COUNTY, ARKANSAS LUNDEN ALEXIS ROBERTS PLAINTIFF ve. Case No:. 32DR-19-187 ROBERT HUNTER BIDEN DEFENDANT [2p iv. | FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS COMES NOW the litigant, by and through counsel, LANCASTER & LANCASTER LAW FIRM, PLLC, and propounds the following Interrogatories and Requests for Production to the defendant to be answered under oath and within the time period specified by the Arkansas Rules of Civil Procedure: INTERROGATORYNO.1. Please list the names, addresses and telephone numbers of all persons whom you intend to call as witnesses in this cause and describe briefly the substance of the testimony of each. INTERROGATORY NO.2. Please list all experts you intend to call and describe their testimony, the basis for any opinions to be rendered, and all treatises, authorities or other resources relied upon by the expert. INTERROGATORY NO. 3. _Please list all experts by name, address, and telephone number that you have retained in this case. INTERROGATORY NO. 4, Please list all banks or other financial institutions used-by you and all business owned or controlled by you for the past five years. (02578 HobortsLandaf2DR).1905To: 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 07/22 all experts you intend to call at any hearing in this matter. REQ. FOR PROD. OF DOCS.NO.7: Please provide all reports of any expert you intend to calll at any hearing of this matter. REQ. FOR PROD. OF DOCS.NO. 8: Please sign and return the attached financial records release. Respectfully Submitted, LANCASTER & LANCASTER LAW FIRM, PLLC P.O. Box 1295 Benton, Arkansas 72018 P: (501) 776-2224 r. Lancaster, 2011179 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been delivered by the below method to the following person or persons: First Class Mail Pacis Df ‘Email [_ | AOC/ECF [_ | Hand Delivery Bart Calhoun Jessica D. Johnston bealhoun@mrefirm.com jessica@bdjlawoffice.com Dustin McDaniel dmedaniel@mrefirm.com on cuogll DAY of AUGUST, 2019. Clinton W. Lancaster 267 Roberts Lndan(22DR) 1905,Tor 18707938888 Prom: 15017786186 -. Date: 12/18/19 ‘Time: 6:51 AM Page: 08/22 2! Lancaster & Lancaster Law Firm, piic ww TheLancasterLawFirin.cou ROBERTS v. BIDEN MOTION TO COMPEL DISCOVERY EXHIBIT NO. 2. SECOND R. 37 GOOD FAITH ATTEMPTTor 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Pager 09/22 Lancaster & Lancaster Law Firm, pitc Clinton W. Lancaster AIBN. Marker Streot Tels (501) 776-2224 P.O. Box 1295 Fax: (501) 778-6186 © Beaton, Arkansas December 9, 2019 Jennifer M. Lancaster www-TheLaneasterLawFirm.com Brent Langdon (blangdon@ldatty.com) (lannis@datty.com) BY EMAIL TO ALL RECIPIENTS RE: LUNDEN ROBERTS v. HUNTER BIDEN IND. CO. CIR. CT. CASE NO.: 32DR-19-187 SECOND RULE 37 GOOD FAITH ATTEMPT Dear Mr. Langdon: Mr. Biden's previous attomeys had objected to answering any of the interrogatories on the basis that service was not perfected and a protective order was needed. The service issue has been resolved and a protective order has been entered. Enclosed with this leter are the original interrogatories, Mr. Biden’s objections, our first Rule 37 good faith attempt, the unredacted request for admissions, and a word document of both discovery documents to make answering them more convenient. Please provide the answers to the interrogatories within ten days (December 19, 2019) or I will file a motion to compel discovery. Also, I calculate the requests for admissions to be due by the close of the clerk’s office on January 6, 2020. on the-issue of| It is my hope that this will avoid the need for a protective order relating to the deposition. If this will not resolve’ Sincerely, ***SETTLEMENT NEGOTATIONS REDACTED PURSUANT TO ARK. R. EVID. 408*** Clinton W. Lancaster Partner, Attomey at Law Jennifer Lancaster , Lunden Roberts ce:To: 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Pager 10/22 2! Lancaster & Lancaster Law Firm, piic wwneTheLaneasterLawFirm.com ROBERTS y. BIDEN MOTION TO COMPEL DISCOVERY. EXHIBIT NO. 3. DEFENDANT’S SUPPLEMENTAL OBJECTIONS TO INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTSTo: 18707938888 Prom: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 11/22 PROVIDED SUBJECT TO COURT'S INTERLOCUTORY ORDER AND PROTECTIVE ORDER 12/04/2019 IN THE CIRCUIT COURT OF INDEPENDENCE COUNTY, ARKANSAS DOMESTIC RELATIONS DIVISION LUNDEN ALEXIS ROBERTS PLAINTIFF v. CAUSE NO. 32DR-19-187-2 ROBERT HUNTER BIDEN DEFENDANT SUPPLEMENTAL RESPONSES AND OBJECTIONS TO:PLAINTIFI’S. FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION To: — Lunden Alexis Roberts, by and through her attomeys of record, Clinton W. Lancaster and Jennifer M. Lancaster, LANCASTER & LANCASTER LAW FIRM, PLLC, P.O. Box 1295, Benton, Arkansas 72018, Defendant, Robert Hunter Biden, provides the following Supplemiental Responses and Objections to Plaintiff's First Set of interrogatories and Requests for Production. . : Respectfully submitted, LANGDON* DAVIS, LLP. 5902 Summerfield, Suite A Texarkana, TX 75505-5547 Tel: (903) 223-3246 Fax {9Q3) 223-5227, By: Brent M-Langdon AR State Bar No. 90042 E-mail: blangdon@datty.com Attorney for DefendantTor 18707938888 From: 15017786186 Date: 12/18/19 ‘Time: 6:51 AM Page: 12/22 CERTIFICATE OF SERVICE I certify that a true copy of the above was served on each attorney of record ot party on the 17" day of December 2019, as follows: Clinton W. Lancaster Via USPS. 1 Class & clint@thelancasterlawfirm.com Jennifer M. Lancaster Via US.P.S. I Class & jennifer@thelancasterlawfirm.com LANCASTER & LANCASTER LAW FIRM, PLLC P.O. Box 1295 Benton, Arkansas 72018 irent M. Langdi Attorney for Defe es Widen ~ Indien Candy AR Wo OR TOTES Page? upplemental Responses and Objections to Plaintiff's Interrogatorics and Request for ProductionTo: 18707938088 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Pager 13/22 INTERROGATORY NO. 4. Please list all banks or other financial institutions used by you and all business owned or controlled by you for the past five years. ANSWER: OBJECTION: Defendant objects to this Interrogatory on the basis the interrogatory is overly broad, unduly burdensome and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The information requested will not lead to admissible evidence. OBJECTION: The disclosure of information responsive to this Interrogatory would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant. Further, to the extent this Request seeks information in possession, custody, or control of any nonparty is withheld as privileged information belonging fo e nonparty. Moreover, the requested information consists of trade secret or proprietary information for which Defendant has «a qualified privilege to refuse to disclose and to prevent others from disclosing. Pursuant to Ark. R. Civ. P 26(c), a Protective Order is sought. OBJECTION: Although Defendant may have access to some information requested in this Interrogatory, Defendant does not have possession, custody, or control of and/or the authority to disclose the requested information. Pursuant to Ark. R. Civ. P 26(c), a Protective Order is sought. ANSWER and MOTION FOR CONFIDENTIALITY ORDER: In the event that the Court orders the disclosure of the requested information in connection with this Interrogatory, Defendant moves the Court to impose an appropriate confidentiality order on Plaintiff and any attorney, consultant, or expert witness of Plaintiff. INTERROGATORY NO. 5. Please state the address in which you reside. ANSWE! OBJECTION: Defendant objects to this Interrogatory on the basis the interrogatory is overly broad aad seeks information which is neither relevant nor material o any claim or defense which would necessarily be limited to the pleadings before the Court. The information requested will not lead to admissible evidence. OBJECTION: The disclosure of information responsive to this Interrogatory would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant and would create a threat to him, Further the information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” the Defendant. Pursuant to Ark. R. Civ. P 26(), a Protective Order is sought. ‘Roberson —Toepeece Cow, AR Wa, SIDR TOTETT Paget ‘Supplemental Responses and! Objections to Plaintiff's Interrogatories and Request for Production, i | i |To: 18707938888 From: 15017786186 Date: 12/18/19 Time: 251 AM Page: 14/22 INTERROGATORY NO. 6. Please state the address where your wife resides. ANSWER: OBJECTION: Defendant objects to this Interrogatory on the basis the interrogatory overly broad and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The information requested will not lead to admissible evidence. OBJECTION: The disclosure of information responsive to this Interrogatory would constitute an impermissible invasion of the personal, property, ot constitutional rights of a non- party and would create a threat to her. Further the information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” a nonparty. Pursuant to’ Ark. R. Civ. P 26(c), a Protective Order is sought. INTERROGATORY NO. 7, Please list all address in which you have tesided in the past five years. ANSWE! OBJECTION: Defendant objects to this interrogatory on the basis the intervogatory is overly broad and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The information requested will not lead to admissible evidence. OBJECTION: The disclosure of information responsive to this Interrogatory would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant and would create a threat to him, Further the information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” Defendant. Pursuant to Ark. R. Civ. P 26(c), a Protective Order is sought. INTERROGATORY NO. 8. Please state if you have received packages or mail at 950 Larrabee Street, APT. 407 iti West Hollywood, California. ANSWEI OBJECTION: Defendant objects to this Interrogatory on the basis the interrogatory ii overly broad and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. ‘The information requested will not lead to admissible evidence. “Taber Bion dipendencs Coty, AR Wo, 2K TET Supplemental Responses and Objections to Plainti's tnterrogatories and Request for Production Fears | | iTor 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 15/22 OBJECTION: The disclosure of information responsive to this Interrogatory would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant and would create a threat to him. Further the information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” Defendant, Pursuant to Ark. R. Civ. P 26(€), a Protective Order is sought. INTERROGATORY NO. 9, Please state your phone number. ANSWEI OBJECTION: Defendant objects to this Intecrogatory on the basis the interrogatory is overly broad and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The information requested will not lead to admissible evidence, OBJECTION: The disclosure of information responsive to this Interrogatory would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant and would create a threat to him. Further the information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” Defendant. Pursuant to Ark. R. Civ. P 26(c), a Protective Order is sought. INTERROGATORY NO. 10. _ Please state your wife’s telephone number. ANSWER: OBJECTION: Defendant objects to this Interrogatory on the basis the interrogatory is overly broad and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The information requested will not lead to admissible evidence. OBJECTION: The disclosure of information responsive to this Interrogatory would constitute an impermissible invasion of the personal, property, or constitutional rights of a non- party and would create a threat to het. Further the information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” a nonparty. Pursuant to Ark. R. Civ: P 26(0), a Protective Order is sought. ERR 11, Please list all companies that you currently own or have an ownership interest in by the name of the company and the state in which itis incorporated, ANSWER: OBJECTION: Defendant objects to this Interrogatory on the basis the interrogatory is ‘oer vB = ndapats Coty, AR; No SIDR TB TET? Tea Supplemental Responses and Objections to Plaintiff's Interrogatories and Request for ProductionTo: 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 16/22 overly broad, unduly burdensome and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The information requested will not lead to admissible evidence. OBJECTION: The disclosure of information responsive to this Interrogatory would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant. ‘The information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” Defendant. Further, to the extent this Interrogatory seeks information of any nonparty, the information responsive to this Interrogatory is withheld as privileged information belonging to anonparty. Moreover, the requested information consists of trade secret or proprietary information for which Defendant has a qualified privilege to refuse to disclose and to prevent others from disclosing. Pursuant to Ark. R. Civ. P 26(c), a Protective Order is sought. OBJECTION: Defendant further dbjects to this Interrogatory on the ground that the request is vague, ambiguous, overly broad, unduly burdensome, does not adequately describe which information is requested or sought with reasonable particularity and would require Defendant to marshal all evidence which would be outside the scope of relevant information to the pleadings before the Court. ANSWER and MOTION FOR CONFIDENTIALITY ORDER: In the event that the Court orders the disclosure of the requested information in connection with this Interrogatory, Defendant moves the Court to impose an appropriate confidentiality order on Plaintiff and any attomey, consultant, or expert witness of Plaintiff. Subject to the foregoing objections and request for protective order, Defendant refers Plaintiff to his Affidavit of Financial Means and tax returns as ordered by the Court. INTERROGATORY NO. 12. Please list all companies that you have had an ‘ownership interest in for the past five years by the name of the company and the state in which it is incorporated. ANSWE! OBJECTION: Defendant objects to this Interrogatory on the basis the intecrogatory is, overly broad and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The information requested will not lead to admissible evidence. OBJECTION: The disclosure of information responsive to this Interrogatory would constitute an irhpermissible invasion of the personel, property, or constitutional rights of Defendant. The information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” Defendant. Further, to the extent this Interrogatory seeks information of any nonparty, the information responsive to this Interrogatory is withheld as privileged information belonging to arson — Teens Candy, AR: No. PDR TBISTS Page? Supplemental Responses anc Objections to Plaintiff's {nterrogatories nnd Request for Pro i i \ i !Tor 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AK Paget 17/22 Anonparty. Moreover, the requested information consists of trade secret or proprietary information for which Defendant has a qualified privilege to refuse to disclose and to prevent others from disclosing, Pursuant to Ark. R. Civ. P 26(c), a Protective Order is sought. OBJECTION: Defendant further objects to this Interrogatory on the ground that the request is vague, ambiguous, overly broad, unduly burdensome, does not adequately describe which information is requested or sought with reasonable particularity and would require Defendant to marshal all evidence which would be outside the scope of relevant information to the pleadings before the Court. ANSWER and MOTION FOR CONFIDENTIALITY ORDER: In the event that the Court, ‘orders the disclosure of the requested information in connection with this Interrogatory, Defendant moves the Court to impose an appropriate confidentiality order on Plaintiff and any attorney, consultant, or expert witness of Plaintiff. Subject to the foregoing objections and request for protective order, Defendant refers Plaintiff to his Affidavit of Financial Means and tax returns as ordered by the Court. INTERROGATORY NO. 13. _ Please list all sources of income you have received for the past five years by source and annual or monthly amount of income. ANSWER OBJECTION: Defendant objects to this Interrogatory on the ground that the request is vague, ambiguous, .overly broad, unduly burdensome, does not adequately describe: which information is requested or sought with reasonable particularity and would require Defendant to marshal all evidence which would be outside the scope of relevant information to the pleadings before the Court. OBJECTION: The disclosure of information responsive to this Interrogatory would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant. The information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” Defendant. Further, to the extent this Interrogatory seeks information of any nonparty, the information responsive to this Interrogatory is withheld as privileged information belonging to anonparty. Moreover, the requested information consists of trate secret or proprietary information for which Defendant has a qualified privilege to refuse to disclose and to prevent others from disclosing. Pursuant to Ark. R. Civ, P 26(c), a Protective Order is sought. Subject to the foregoing objections and request for protective order, Defendant refers Plaintiff to his Affidavit of Financial Means and tax returns as ordered by the Court. INTERROGATORY NO. 14. _Please list all of your employers for the past five years by name of employer, address of employer, and mount of compensation. ‘obra Biden Tadepenecx Coy, AR: No DR TRIE Snpplementat Responses and Objections to PlaintifPs Interrogat Page jes nad Request for Production i 'To: 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 18/22 ANSWER: OBJECTION: Defendant objects to this Interrogatory on the basis the interrogatory is overly broad and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The information requested will not lead to admissible evidence. OBJECTION: The disclosure of information responsive. to this Interrogatory would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant. The information sought is only for the purpose to unreasonably “annoy, embacrass, ot oppress” Defendant. Further, to the extent this Interrogatory seeks information of any nonparty, the information responsive to this Interrogatory is withheld as privileged information belonging to anonparty. Moreover, the requested information consists of trade secret or proprietary information for which Defendant has a qualified privilege to refuse to disclose and to prevent others from disclosing. Pursuant to Ark. R. Civ. P 26(c), a Protective Order is sought, OBJECTION: Defendant further objects to this-Interrogatory on the ground that the request is vague, ambiguous, overly broad, unduly burdensome, does not adequately describe which information is requested or sought with reasonable particularity and would require Defendant (o marshal all evidence which would be outside the scope of relevant information to the pleadings before the Court. Subject to the foregoing objections and request for protective order, Defendant refers Plaintiff to his Affidavit of Financial Means and tax returns as ordered by the Court. INTERROGATORY NO. 15. _Please describe all exhibits you intend to.use at trial and why you think they are legally or factually (or both) significant. ANSWEI Defendant refers Plaintiff to his Affidavit of Financial Means and tax returns as ordered by the Court, INTERROGATORY NO. 16. Will you consider the foregoing Interrogatories and Requests For Production of Documents as continuing and furnish by way of supplemental response such additional information as may be acquired which updates. or modifies answers to the foregoing, such supplemental responses to be served at least ten days before the assigned wial date? ‘ober. Widen ~ independance Con, A; No S3DRIBEN. Supplemental Responses and Objections to Plaintif's tnterrogatories aud Request for Production FagsTot 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 19/22 ANSWER: Defendant will comply with the Arkansas Rules of Civil Procedure. REQ. FOR PROD. OF DOCS.NO. 1; Please produce an unredacted copy of your personal state and federal income tax retums for the past five years. RESPONS! OBJECTION: Defendant objects to this Request on the basis the request is overly broad and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The documents requested will not lead to admissible evidence. OBJECTION: The disclosure of information responsive to this Request would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant, The information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” Defendant. Further, to the extent this Interrogetory seeks information of any nonparty, the information responsive to this Interrogatory is withheld as privileged information belonging to a nonparty. Moreover, the requested information consists of trade secret or proprietary information for which Defendant has © qualified privilege to refuse to disclose and to prevent others from disclosing. Pursuant to Ark. R. Civ. P 26(c), a Protective Order is sought. Subject to the foregoing objections and request for protective order, Defendant refers Plaintiff to his tax returns provided to the Court and counsel REQ. FOR PROD. OF DOCS.NO. 2: Please produce an unredacted copy of all state and federal income tax returns for any business you own or have had an ownership interest for the past five years. RESPONSE: OBJECTION: Defendant objects to this Request on the basis the request is overly broad andl seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The documents requested will not lead to admissible evidence. OBJECTION: Defendant further objects to this Interrogatory on the ground that the request is unduly burdensome, particularly regarding the scope of relevant information to the pleadings before the Court. Takers Win Independence Conny, AR: Ro IDR TBTETE Fee TO Supplemental Responses and Objections to PlaintifP's tnterrogatories aad Request for Production‘To: 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 20/22 OBJECTION: The disclosure of information responsive to this Request would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant. The information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” Defendant. Further, to the extent this Request seeks information of any nonparty, the information responsive to this Request is withheld as privileged information belonging to a nonparty. Moreover; the requested information consists of trade secret or proprietary information for which Defendant has a qualified privilege to refuse to disclose and to prevent others from disclosing. Pursuant to Ack. R. Civ, P 26(c), a Protective Order is sought. OBJECTION: Although Defendant may have access to some information requested in this Request, Defendant does not have possession, custody, or control of and/or the authority to disclose or produce documents or tangible items responsive to this request. Ark. R. Civ. P26(e), 1 Protective Order is sought. RESPONSE and MOTION FOR CONFIDENTIALITY ORDER: In the event that the Court orders the production of documents and tangible items in connection with this Request, Defendant moves the Court to impose an appropriate confidentiality order on Plaintiff and any attorney, consultant, or expert witness of Plaintiff. Subject to the foregoing objections and request for protective order, Defendant refers Plaintiff to his tax returns provided to the Court and counsel, REQ. FOR PROD. OF DOCS.NO.3: Please provide all deeds to all property in which you have an ownership interest or have had an interest in during the last five (5) years. RESPONS! OBJECTION: Defendant objects to this Request on the basis the request is overly broad and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The documents requested will not lead to admissible evidence. OBJECTION: Defendant further objects to this Interrogatory on the ground that the request is unduly burdensome, particularly regarding the scope of relevant information to the pleadings before the Court, OBJECTION: The disclosure of information responsive to this Request would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant. The information sought is only for the purpose to unreasonably “annoy, embarrass, or oppress” Defendant. Further, to the extent this Request seeks information of any nonparty, the information responsive to this Request is withheld as privileged information belonging to a nonparty. ‘Moreover, the requested information consists of trade secret or proprietary information for which Defendant has a qualified privilege to refuse to disclose and to prevent others from disclosing Pursuant to Ark. R. Civ. P 26(c), a Protective Order is sought. etsy Biden ~Tndpardonca Cony, A Ne S2DICTBET? ipplemental Responses and Objections to Plaintiff's tnterrogatories and Request for ProductionTor 18707938888 From: 15017786186 Date: 12/18/19 Time: 6:51 AM Page: 21/22 OBJECTION: Although Defendant may have access to some information requested in this Request, Defendant does not have possession, custody, or control of documents or tangible items responsive to this request, Ark. R. Civ. P 26(¢), a Protective Order is sought. RESPONSE and MOTION FOR CONFIDENTIALITY ORDER: In the event that the Court orders the production of documents and tangible items in connection with this Request, Defendant moves the Court to impose an appropriate confidentiality order on Plaintiff and any attomey, consultant, or expert witness of Plaintiff. REQ. FOR PROD. OF DOCS.NO. 4: Please attach a copy of all documents, charts, grafts, summaries, photographs, or other exhibits you intend to introduce or utilize at the trial of this action to your answeis. RESPONSE: Defendant refers Plaintiff to his Affidavit of Financial Means and tax retums as ordered by the Court. REO. FOR PROD. OF DOCS.NO.5: Please produce all reports, memoranda, photographs, slides, videotapes, audiotapes, or other written or recorded media containing any information gathered during any periods of observation or surveillance of the other party. This request includes, without limitation, any audiotapes of conversations between you and the other party, as well as third party conversations REQ. FOR PROD. OF DOCS.NO.6; Please provide a curriculum vitale of all experts you intend to call at any hearing in this matter. RESPONSE: NIA "Robart Biden — Tipo Conny ATE: Wo ‘Supplemental Responses and Objecti SOR IETETT Page 1? to Plaintiff's Tnterrogatories and Request for Production‘To: 18707938888 From: 15017786186 Date: 12/18/19 ‘Time: 6:51 AM Page: 22/22 REQ. FOR PROD. OF DOCS.NO.7: _ Please provide all reports of any expert you intend to call at any hearing of this matter, + RESPONSE: NA REQ. FOR PROD. OF DOCS.NO. 8: Please sign and return the attached financial records release. RESPONSE: OBJECTION: Defendant objects to this Request on the basis the request is overly broad and seeks information which is neither relevant nor material to any claim or defense which would necessarily be limited to the pleadings before the Court. The documents requested will not lead to admissible evidence. OBJECTION: Defendant further objects to this Interrogatory on the ground that the request is unduly burdensome, particularly regarding the scope of relevant information to the pleadings before the Court. OBJECTION: The disclosure of information responsive to this Request would constitute an impermissible invasion of the personal, property, or constitutional rights of Defendant. “The information sought is only for the purpose to unreasonably “annoy, embarrass, of oppress” Defendant. Further, to the extent this Request secks information of any nonparty, the information. responsive to this Request is withheld as privileged information belonging to a nonparty. Moreover, the requested information consists of trade secret or proprietary information for which Defendant has a qualified privilege to refuse to disclose and to prevent others from disclosing. Pursuant to Ark. R. Civ. P 26(c), a Protective Order is sought. OBJECTION: Although Defendant may have access to some information requested in this. Request, Defendant does not have possession, custody, or control of and/or the authority to ‘disclose or produce documents or tangible items responsive to this request. Ark. R. Civ. P 26(c), a Protective Order is sought. RESPONSE and MOTION FOR CONFIDENTIALITY ORDER: In the event that the Court orders the production of documents and tangible items in connection with this Request, Defendant moves the Court to impose an appropriate confidentiality order on Plaintiff and any attorney, consultant, or expert witness of Plaintiff. Subject to the foregoing objections and request for protective order, Defendant has complied with the Court’s order for disclosure of his financial information for puxposes of calculating net income for child support. Taber Bden —Tedipandance Coe AR Fa, AOR TORT Pope 73 ‘Supplemental Responses and Objections to Plaintif?'s interrogatories and Request for Production