22nd JUDICIAL DISTRICT COURT

PARISH OF ST TAMMANY
STATE OF LOUISIANA

NUMBER: 2021-12393 DIVISION: K

MICHAEL A. BREWER

VERSUS

MELISSA V. BREWER

Filed: ____________________ Deputy Clerk: _____________________

INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS

TO: MICHAEL A. BREWER

14605 Park Road
Biloxi, MS 39532

NOW COMES, MELISSA V. BREWER, through undersigned counsel, and propounds

to MICHAEL A. BREWER the following interrogatories to be answered fully, individually, in
writing, and under oath under the provisions of the Louisiana Code of Civil Procedure, within
fifteen days; and in default of the full, complete, and timely answer thereto, MELISSA V.
BREWER demands that MICHAEL A. BREWER pay all reasonable attorney's fees, costs, and
expenses of compelling answer to same.

These interrogatories cover all information available to the answering party and to each and
every agent, employee, and attorney of such party, whether by personal knowledge, hearsay, books,
records, reports, or any other sources, and these interrogatories are continuing, and the answers shall
be supplemented or amended if further information becomes known to the answering party prior to
the trial of this case.

Now further comes, MELISSA V. BREWER, through undersigned counsel, and under the
provisions of the Louisiana Code of Civil Procedure Articles 1461 and 1469, requests that you
produce for inspection and copying the following described documents at 404 Parish Drive, Arabi,
Louisiana, 70032, within fifteen days; and that, in the event you fail to comply with this request,
you pay all reasonable costs, expenses, and attorney's fees for obtaining an order compelling the
production of these documents under the provisions of Article 1469 of the Louisiana Code of Civil
Procedure.

INTERROGATORIES
INTERROGATORY NO.1:
Do you have ownership or equitable interest in any business or business transaction of any
kind? If so, please state:
a. The name and address of each such business, and your percentage of interest therein;
b. The form of that business operation, i.e., a sole proprietorship, joint venture,
partnership, corporation, etc.;
c. Whether any other person has an ownership or equitable interest in that business, and if
so, state the name, address, and nature and percentage of such interest,
d. Whether you believe it is community property or separate property; and
e. If you believe that this account is your separate property, please give all reasons why you
believe this.
If this business has been sold, please indicate the date of sale, who it was sold to and the
proceeds received from the sale.
INTERROGATORY NO.2:
List all of the immovable property in which you have, or had, a legal or equitable ownership
interest from August 20, 2004, to present, stating for each such property:
a) Acquisition date; and
b) Initial down payment (source and amount).

Has this property been sold? If so, for how much, to whom and when?
If not, please answer the following:
a) What mortgages are outstanding on this property, and for each such mortgage state the
mortgagor's name and address, the periodic payments, and the balance owed on each
mortgage as of this date;
b) Your estimate of current fair market value; and
c) Whether you consider this asset to be community property or separate property.

If you believe that this asset is your separate property, please give all reasons why you believe
this.

INTERROGATORY NO.3:
Do you maintain, or does someone maintain on your behalf, a safety deposit box? If so, state as
to each such safety deposit box:
a) The institution in which it is maintained;
b) The address of that institution;
c) The number of other identifying nomenclature for this box;
d) Contents of the box;
e) The signatories for the box; and
f) The last date that you had entry to this safety deposit box.

INTERROGATORY NO. 4
List every type of insurance policy, whether life, health, disability or other, owned by you,
stating for each such policy:
a) The name of the insurer;
b) The policy number;
c) Date of issuance;
d) Type of policy;
e) Face value;
f) Cash surrender value as of August 20, 2004, and present; and
g) Beneficiary.

Is there a loan against the policy? If so, please state what is the amount of the loan outstanding at
present, who obtained that loan, when obtained, and for what purpose was the loan obtained; and
Owner of the policy.

INTERROGATORY NO.5:
List all motor vehicles, watercrafts, and airplanes, etc. owned by you or by someone on your
behalf, as of the present date.

INTERROGATORY NO.6:
List and describe each pension, retirement, or similar type of plan in which you have a present or
future interest of any kind.

INTERROGATORY NO.7:
List each liability owed by you or your spouse, as of present date, stating for each:
a) Name and address of creditor;
 b) The amount owed as of that date;
c) Monthly payments required;
d) Date upon which obligation was incurred; and
e) Purpose for which obligation was incurred.

INTERROGATORY NO. 8:
Please state whether you have furnished a financial statement or statements to any banks or
lending institutions, within the past three (3) years. If so, please state for each individual
statement, the date on which the statement was furnished, and the name of the bank or institution
to whom the statement was furnished.

INTERROGATORY NO. 9
Please provide a list of any and all banks and lending institutions or individuals with which you
individually borrowed funds or with which you have guaranteed borrowing from January 1,
2015, through the present.

INTERROGATORY NO. 10:

Please list any and all benefits offered to you or received by you from your employer(s) in
addition to the income reported in the pay stubs and/or federal income tax forms, including but
not limited to a company automobile, clothing, meals, boarding, charge privileges, travel
expenses or reimbursements, and/or other employee benefits, in the past ten (10) (5) years.

INTERROGATORY NO. 11
Please provide the name, address, telephone number, of each witness (stating whether each
witness will testify as a fact witness or expert witness and provide the actual substance of each
witness' testimony) that you may call to testify in this proceeding.

INTERROGATORY NO. 12:

Identify all assets of the community, including current fair market value and location, and all
liabilities of the community.

INTERROGATORY NO. 13:

Identify with particularity all of your alleged separate assets and liabilities, and state their values
as of August 20, 2004, or as close thereto as practicable, and as of the present date, or as close
thereto as practicable, and explain in detail why you believe these assets or liabilities are separate
in nature.

INTERROGATORY NO. 14:

Please list your income from all sources, active or passive, from January 1, 2015, to date,
identifying each source of income and the gross and net amount received from that source.

REQUEST FOR PRODUCTION OF DOCUMENTS

REOUEST FOR PRODUCTION OF DOCUMENTS NO.1:

Please produce any and all documentation utilized or referred to in order to respond to
the Interrogatories submitted herewith.

REOUEST FOR PRODUCTION OF DOCUMENTS NO.2:

Please produce copies of all documents, exhibits, physical items, and other demonstrative
evidence which you may or will use or introduce at the hearing or trial of any and all matters
pending herein, including, without limitation, requests for spousal support and child support,
and the property partition, including any aspect thereof relative to direct examination, cross
examination, redirect examination, or as rebuttal or impeachment evidence of any party or
witness.
REQUEST FOR PRODUCTION OF DOCUMENTS NO.3:
Please produce copies of all federal and state income tax returns filed by you, or on your behalf;
together with all schedules and work sheets, including W-2 forms, 1099s, 1098s, and other tax
reporting forms, for tax years 2015 to date, If tax returns have not been filed, please produce all
documents which will be used to prepare such tax returns, including, but not limited to, tax
reporting forms requested herein.

REQUEST FOR PRODUCTION OF DOCUMENTS NO.4:

Please produce copies of federal and state tax returns and all financial statements of any nature or
kind for any and all corporations, joint ventures, partnerships or other corporate or business
entities, including sole proprietorships, in which you hold or held an interest, for the tax years
January 1, 2015, to date.

REOUEST FOR PRODUCTION OF DOCUMENTS NO.5

Please produce all corporate or other business formation documents, minutes, and yearly reports,
including all Articles of Incorporation / Organization; partnerships; L.L.C.'s; L.L.P.'s; By-Laws;
Operating Agreements; Shareholders' Agreements; stock certificates, etc., from January 1, 2004,
to date, for all business entities in which you have or had an interest, and including, without
limitation, joint ventures and proprietorships.

REOUEST FOR PRODUCTION OF DOCUMENTS NO.6:

Please produce a copy of your paycheck stubs and/or other such similar statements from your
employer, or if you are self-employed, a statement signed by you, showing all wages, salaries,
bonuses, commissions, earnings, income, payroll deductions, other deductions of any kind, and
all employment contracts, pay raises, promotions, and reimbursable expenses to which you are
entitled to from August 20, 2004, to date.

REOUEST FOR PRODUCTION OF ROCUMENTS NO.7

Please produce all records that related to any secured or unsecured personal loan made to you
from August 20, 2004, to date, whether from a member of your family, a bank institution, or any
individual or entity.

REOUEST FOR PRODUCTION OF DOCUMENTS NO.8:

Please produce copies of all checking accounts in your name individually, with another, as
trustee or as guardian, or in which you have an interest, including canceled checks,
checkbooks, check registers, deposit slips, and monthly statements (regardless of whether or
not the account or accounts have been closed), including, but not limited to, any and all
personal, partnership, corporate, or other legal entity accounts, including sole proprietorships,
on which you have signatory privileges or in which you have or had an interest from August
20, 2004, to date.

REOUEST FOR PRODUCTION OF DOCUMENTS NO.9:

Please produce all bank books of any kind or nature, including, without limitation, all passbooks,
bank books, and/or certificates of deposit, showing any balance listed in your name, or for your
account, individually or with any other party, from August 20, 2004, to date.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 10:

Please produce copies of all credit cards and charge accounts held by you or on your behalf, and
all statements and receipts received by you in connection with the use of such credit cards and
charge accounts from August 20, 2004, to date, whether in your name, another's name, or the
name of any business entity which you are authorized to incur charges.
REOUEST FOR PRODUCTION OF DOCUMENTS NO. 11
Please produce copies of all financial statements, loan applications or records containing
financial information of any nature which have been submitted by you to banks, lending
institutions, or to any person or entities, in connection with your application for credit or loans
from August 20, 2004, to date, and/or submitted by you or by any partnership, corporation, or
business entity in which you have or had an interest.

REOUEST FOR PRODUCTION OF DOCUMENTS NO. 12:

Please produce copies of all life, health and medical, homeowner's, and automobile insurance
policies under which you and/or your wife have coverage, and please produce copies of all
statements reflecting cash surrender values, policy loans, and premium costs for such policies, as
well as all documents evidencing payment of such premium costs, from August 20, 2004, to
date.

REOUEST FOR PRODUCTION OF DOCUMENTS NO. 13:

Please produce copies of any and all contracts of employment entered into by you from
August 20, 2004, to present.

REOUEST FOR PRODUCTION OF DOCUMENTS NO. 14:

Please provide copies of computer generated data or backups from any and all personal or
business accounting software which you have used or is being used on your behalf in the last
ten (10) years, including, but not limited to, Quicken, Quick Books, Microsoft Money,
Peachtree, etc.

REOUEST FOR PRODUCTION OF DOCUMENTS NO. 15:

Please produce copies of any declaration of separateness, paraphernality, marital contract or
matrimonial agreement or any type of documents of this nature executed by you from August 20,
2004, to present.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 16:

Please produce copies of any and all contracts, memoranda, correspondence, notes and other
documents prepared by, or between, you and/or your spouse or any other person, relating in any
way to any change in the character of property then owned or to be acquired by either you and/or
your spouse, entered into or prepared (whether or not actually executed) at any time up to and
including the date of production or at any time during the marriage.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 17:

Please provide copies of any and all contracts, correspondence, memoranda and any other
records or writings upon which you base the connection that the property is community, quasi-
community or your separate property and/or your spouse's separate property.

REOUEST FOR PRODUCTION OF DOCUMENTS NO. 18:

Please produce copies of any and all trust agreements, fiduciary income tax returns,
correspondence, periodic accounting and any other documentation related to any trust in which
you and/or your spouse has had an interest from August 20, 2004, to the date of the production of
these documents.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 19

Please produce copies of any and all gift tax returns, both state and federal, filed by you and/or
your spouse, and any other documents reflecting gifts made by you or your spouse to one another
or to any third person during the period from August 20, 2004, to the date of the production of
these documents.
REOUEST FOR PRODUCTION OF DOCUMENTS NO. 20:
Please produce all documentation for any benefits provided to you by your employer for the last
ten (10) years other than salaries and bonuses. Such documentation shall include, but not
necessarily be limited to:
a) Expense Reimbursements
b) Loans
c) Retirement benefits
d) Direct payments for meals, travel, entertainment, etc.
e) Health Insurance.
f) Automobile(s) and related costs.

REQUEST FOR PRODUCTION OF DOCUMENTS NO 21:

Please produce title and registration and mortgage documents for all vehicles in your name or
held in the name of another for your benefit at the present time, or any time in the last ten (10)
years.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 22:

Please produce all documentation regarding any real estate titled in your name, or in the name of
a third party or business entity for your benefit as of the present time or any time from August
20, 2004, to present. Such documentation shall include, but not necessarily be limited to
acquisition documents, sales documents, settlement statements, mortgage documents, loan
histories, amortization schedules, loan statements and appraisals.

REOUEST FOR PRODUCTION OF DOCUMENTS NO. 23:

Please produce all documentation regarding all investments in your name, your wife's name or in
the name of a third party or business entity for your benefit, including, but not necessarily limited
to stocks, bonds, certificates of deposit, savings accounts, brokerage accounts, etc., for the last
ten (10) years.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 24:

Please produce all documentation regarding any retirement benefits (IRAs, 401k plans, defined
benefit plans, etc. in your name for the last ten (10) years. Such documentation shall include, but
not necessarily be limited to account statements and summary plan description(s).

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 25:

Please produce all documentation regarding any loans, whether secured or unsecured, made by
you during the past ten (10) years. Such documents shall include, but not necessarily be limited
to mortgages, line of' credit agreements, notes, collateral documents, guarantees, loan histories
and/or statements of account.

REOUEST FOR PRODUCTION OF DOCUMENTS NO. 26

Please produce any and all documentation regarding any notes receivable, accounts receivable,
or any other receivables owed to the community, or to you personally, whether secured or
unsecured, which are outstanding at the present time or any time in the past ten (10) years. Such
documentation shall include, but not necessarily be limited to notes, mortgages, amortization
schedules documentation regarding payments, any written demands for payment, etc.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 27:

Please produce any documentation related to any reimbursement claims which you have or may
in the future assert in these proceedings against the former community of acquets and gains or
against the separate estate of MELISSA V. BREWER.
REQUEST FOR PRODUCTION OF DOCUMENTS NO. 28:
Please produce any and all documentation regarding any liabilities of the community
existing as of August 27, 2021, secured or unsecured.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 29:

Please produce all documentation regarding your ownership interest in any closely held
corporations, partnerships, sole proprietorships, limited liability companies including, but not
limited to, an such entities "doing business as" any of the above. Such documentation shall
include, but not necessarily be limited to the following:
a) Financial statements for the last ten (10) years (whether internally or externally
prepared);
b) Income tax returns for the last ten (10) years;
c) General ledgers and accounting journals for the last ten (10) years (i.e., payroll journals,
cash receipts and disbursement journals, etc.);
d) All articles of incorporation, by-laws, partnership agreements, operating agreements,
minutes, etc.;
e) Stock book and stock certificates;
f) All buy-sell agreements, or similar agreements, which are currently in effect or which
have been in effect in the last ten (10) years;
g) All checking account records (bank statements canceled checks, debit and credit memos,
check registers, etc.) for the last ten (10) years;
h) Payroll tax returns for the last ten (10) years;
i) All credit card statements for the last ten (10) years;
j) Any business forecasts or projections, or business plans which have been prepared in the
last five (5) years;
k) Any and all documentation regarding the purchase, sale or issuance of stock to any third
parties within the last ten (10) years including, but not necessarily limited to, sales or
acquisition agreements, stock certificates, etc.;
l) Any valuations performed with respect to the stock or assets of this entity (including any
valuations of any patents or other intangible assets), whether internally or externally
prepared, within the past five (5) years;
m) Any and all documentation regarding any secured or unsecured loan executed by this
entity for all debt currently outstanding or which has been outstanding within the past ten
(10) years. Such documentation shall include, but not necessarily be limited to:
1) promissory notes,
2) mortgage documents, loan agreements,
3) line of credit agreements,
4) collateral mortgage instruments,
5) loan applications, and
6) all other documents submitted to a bank or financial institution(s) in connection
with procuring such loan(s);
n) Any and all documentation regarding any patents currently held by this entity, currently
pending before applicable governmental agencies, or in the process of being developed
and/or submitted to applicable governmental agencies;
o) All documentation concerning any claims either actually made or to be made in the future
related to the British Petroleum oil spill which occurred on April 20, 2010, including any
direct or indirect damages;
p) All documentation concerning any claims either actually made or to be made in the future
related to Hurricane Ida, which occurred on August 29, 2021, including any direct or
indirect damages;
q) Any and all contracts entered with the United States Government, British Petroleum or
any third parties, related to any work associated with the British Petroleum oil spill that
occurred on April 20, 2010;
 r) Any and all contracts entered with the United States Government, or any third parties,
related to any work associated with Hurricane Ida that occurred on August 29, 2021;
s) Any and all valuations prepared by you or by another person on your behalf in the last
five (5) years; and
t) Any and all documentation concerning the sale of any businesses during the last ten (10)
years. Such documentation shall include, but not necessarily be limited to the actual sales
documents, covenants not to compete, deferred or contingent payout arrangements, notes
receivable, etc.

Respectfully Submitted,

__________________________
RUSSELL STEGEMAN #08224
506 Water Street
Madisonville, LA 70447
Phone: (985) 800-2001
Email: russell@theshark.us

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the above and foregoing Interrogatories, Request
for Production of Documents and Request for Admissions has been served upon MICHAEL A.
BREWER, via electronic mail and/or United States Postal Service this November 19, 2022.

______________________
RUSSELL STEGEMAN