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Ford v. Advantage Plus Consulting, Inc.

United States District Court, D. Nevada

February 26, 2018

CHERYL FORD, an individual, Plaintiff,
v.
ADVANTAGE PLUS CONSULTING, INC., a Nevada corporation as successor in interest to AFRC, Inc., a Nevada corporation; DOES I-X; individually; and ROE CORPORATIONS I-X, Defendants.

          LAW OFFICE OF HAYES & WELSH, LARSON A. WELSH, ESQ. Attorneys for Plaintiff, CHERYL FORD

          ORDER ALLOWING EXAMINATION OF JUDGMENT DEBTOR, ADVANTAGE PLUS CONSULTING, INC.

         Pursuant to Plaintiff/Judgment Creditor's Application for Order Allowing Examination of Judgment Debtor, Advantage Plus Consulting, Inc., and the Court having reviewed the papers and pleadings on file herein, and good cause appearing:

         IT IS HEREBY ORDERED that ANTHONY ALONSO, President, Secretary and Treasurer of the corporate Defendant and as the person most knowledgeable for Defendant, ADVANTAGE PLUS CONSULTING, INC., appear before Plaintiffs attorney of record, the Law Office of Hayes & Welsh, located at 199 N. Arroyo Grande Blvd., Ste. 200, Henderson, NV 89074 on March 21, 2018, at 9:30 a.m., and on such further days as Judgment Creditor may name, to testify under oath concerning Judgment Debtor's property;

         IT IS FURTHER ORDERED that ANTHONY ALONSO as the person most knowledgeable for Defendant, shall bring all of the documents listed on attached Exhibit 1 to the Judgment Debtor Examination and shall make such documents available for Plaintiffs counsel for inspection and copying;

         IT IS FURTHER ORDERED that the document production required herein applies to Defendant, ADVANTAGE PLUS CONSULTING, INC., individually and to any business in which it has an ownership interest. SAID JUDGMENT DEBTOR IS HEREBY FORBIDDEN IN THE INTERIM FROM DISPOSING OF ANY PROPERTY NOT EXEMPT FROM EXECUTION, INCLUDING ANY AND ALL CASH INFUSIONS RECEIVED BY JUDGMENT DEBTOR. Failure to appear at the time and place as stated above may result in a bench warrant being issued for your arrest; and

         IT IS FURTHER ORDERED that this Order shall be regularly served upon Debtor personally, or upon Debtor's counsel of record.

         IT IS SO ORDERED:

         EXHIBIT 1

         All of the documents listed below apply to the debtor personally and the debtor's spouse:

         1. Your social security number and a copy of your driver's license.

         2. All passports used for travel outside of the United States.

         3. Federal and state income tax returns, W-2 forms, 1099 forms, and any quarterly estimates of federal or state income taxes, for the last four years, including but not limited to requests for extensions to file.

         4. Any and all documents and records of checking, savings, or any other type of account, foreign or domestic, held by you or jointly with any other person, with any type of financial institution during the last four years, including but not limited to monthly account statements, checks, check registers, check stubs, cancelled checks, and deposit slips.

         5. All keys and documents related to any and all safe deposit boxes or other secured vault, whether privately maintained or in any financial institution, belonging to you, or in which you have, or have had an interest whatsoever, either alone or jointly, with any other person or persons for the last four years, and all documents relating to that safe deposit box/secured vault.

         6. Any and all signature cards that name you as an authorized signatory on any financial account, for any entity or other third party, for the last four years.

         7. Any and all documents describing and identifying any brokerage accounts, stocks, bonds, money market accounts, debentures, certificates of deposit, mutual funds, or any other investment vehicle owned by you or held for your benefit for the last four years.

         8. Any and all documents related to any account in which your earnings or other income have been deposited into in the last four years, whether you continue to have an interest in it or not.

         9. Any and all documents evidencing any application signed by you, on your behalf, by your spouse and/or children, to open a foreign or offshore ...


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