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REC’D & FILED
2014 JAN 13 PM 4:16
ALAN GLOVER CLERK
BT DEPUTY __________
Case No. 09 OC 00579 1B
Dept. No. I
In The First Judicial District Court of the State of Nevada
In and for Carson City
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JED MARGOLIN, an individual, Plaintiff, VS.
OPTIMA TECHNOLOGY CORPORATION, a California corporation, OPTIMA TECHNOLOGY CORPORATION, a Nevada corporation, REZA ZANDIAN aka GOLAMREZA ZANDIANJAZI aka GHOLAM REZA ZANDIAN aka REZA JAZI aka J. REZA JAZI aka G. REZA JAZI aka GHONONREZA ZANDIAN JAZI, an individual, DOE Companies 1-10, DOE Corporations 11-20, and DOE Individuals 21-30, Defendants.
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This matter comes before the Court on Plaintiff JED MARGOLIN's Motion for Debtor Examination and to Produce Documents, filed on December 11, 2013.
The Court finds that Defendants have not opposed the Motion for Debtor Examination and to Produce Documents. The non-opposition by Defendants to Plaintiff s Motion constitutes a consent to the granting of the motion.
The Court finds good cause exists to grant Plaintiff s Motion for Debtor Examination and to Produce Documents.
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NOW, THEREFORE, IT HEREBY IS ORDERED as follows:
1. That Defendant REZA ZANDIAN aka GOLAMREZA ZANDIANJAZI aka GHOLAM REZA ZANDIAN aka REZA JAZI aka J. REZA JAZI aka G. REZA JAZI aka GHONONREZA ZANDIAN JAZI is hereby ordered to appear before the Court and answer upon oath or affirmation concerning Defendant's property at a Judgment Debtor Examination under the authority of a Judge of the Court on the following date February 11, 2014 @ 9:00am and
2. That Defendant REZA ZANDIAN aka GOLAMREZA ZANDIANJAZI aka GHOLAM REZA ZANDIAN aka REZA JAZI aka J. REZA JAZI aka G. REZA JAZI aka GHONONREZA ZANDIAN JAZI is hereby ordered to produce to Mr. Margolin's counsel at least one week prior to the Judgment Debtor Examination, so that counsel may effectively review and question Zandian regarding the documents, all information and documents identifying, related to, and/or comprising the following:
a. Any and all information and documentation identifying real property, computers, cell phones, intellectual property, vehicles, brokerage accounts, bank deposits and all other assets that may be available for execution to satisfy the Judgment entered by the Court, including, but not limited to, information relating to financial accounts, monies owed to Zandian by others, etc.
b. Documents sufficient to show Zandian's balance sheet for each month for the years 2007 to the present.
c. Documents sufficient to show Zandian's gross revenues for each month for the years 2007 to the present.
d. Documents sufficient to show Zandian's costs and expenses for each month for the years 2007 to the present.
e. All tax returns filed by Zandian with any governmental body for the years 2007 to the present, including all schedules, W-2's and 1099's.
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f. All of Zandian's accounting records, computerized electronic and/or printed on paper format for the years 2007 to the present.
g. All of Zandian's statements, cancelled checks and related banking documents for any bank, brokerage or other financial account at least partially controlled by Zandian, or recorded in the name of Zandian or for Zandian's benefit, for the years 2007 to the present.
h. All of Zandian's checkbooks, checkbook stubs and checkbook entries for the years 2007 to the present.
i. Documents sufficient to show the means and source of payment of Zandian's current residence and any other residence for the years 2007 to the present.
j Documents sufficient to show the means and source of payment of Zandian's counsel in this matter.
k. Any settlement agreements by which another party has agreed to pay money to Zandian.
DATED: This 13th day of January, 2014.
_________________________________________
JAMES T. RUSSELL
DISTRICT COURT JUDGE
Respectfully submitted by,
WATSON ROUNDS, P.C.
By: ______________________
Adam P. McMillen, Esquire
Nevada Bar No. 10678
5371 Kietzke Lane
Reno, NV 89511
Telephone: (775) 324-4100
Facsimile: (775) 333-8171
Email: amcmillen@watsonrounds.com
Attorney for Plaintiff
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CERTIFICATE OF SERVICE
Pursuant to NRCP 5(b), I certify that I am an employee of Watson Rounds, and that on this date, I deposited for mailing, in a sealed envelope, with first-class postage prepaid, a true and correct copy of the foregoing document, Proposed Order Granting Motion for Debtor Examination and for Production of Documents, addressed as follows:
Geoffrey W. Hawkins, Esquire
Johnathon Fayeghi, Esquire
Hawkins Melendrez, P.C.
9555 Hillwood Drive, Suite 150
Las Vegas, Nevada 89134
Alborz Zandian
9 Almanzora
Newport Beach, CA 92657-1613
Optima Technology Corp.
A California corporation
8401 Bonita Downs Road
Fair Oaks, CA 95628
Optima Technology Corp.
A Nevada corporation
8401 Bonita Downs Road
Fair Oaks, CA 95628
Optima Technology Corp.
A California corporation
8775 Costa Verde Blvd. #501
San Diego, CA 92122
Optima Technology Corp.
A Nevada corporation
8775 Costa Verde Blvd. #501
San Diego, CA 92122
Dated: January 9, 2014
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Nancy R. Lindsley
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