UNITED STATES BANKRUPTCY COURT
`EASTERN DISTRICT OF MICHIGAN
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`
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`
`
`Case No. 22-31772-jda
`Chapter 11 proceeding
`Subchapter V
`Hon. Joel D. Applebaum
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`Adv. No. 23-03064-jda
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`v.
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`
`In re:
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`ENERGY DRILLING SERVICES, LLC,
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`_________________________________/
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`ENERGY DRILLING SERVICES, LLC,
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`ENERGY SITE SERVICES, LLC,
`THE MINORITY ALLIANCE GROUP, LLC,
`KAITLYN ADLER, and JEROME BARRY, III
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`Defendants.
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`
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`_________________________________/
`
`
`Plaintiff,
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`
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`PLAINTIFF’S FIRST SET OF WRITTEN DISCOVERY REQUESTS TO DEFENDANTS
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`Plaintiff, Energy Drilling Services, LLC, propounds its First Set of Written Discovery
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`Requests upon Defendants, Energy Site Services, LLC, The Minority Alliance Group,
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`LLC, Kaitlyn Adler, and Jerome Barry, III, pursuant to FED. R. CIV. P. 26, 33, 34, and 36,
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`as incorporated and applicable to this bankruptcy proceeding pursuant to BANKR. R. 7026,
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`7033, 7034, and 7036, and Local Rules 7026-1 – 4.
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`INSTRUCTIONS
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`1.
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`Please furnish all information, however obtained, that is within your
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`knowledge, possession, or control, or which may be reasonably ascertained by you.
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`2.
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`Please supplement the initial responses to this discovery in writing to
`
`undersigned counsel after service of the responses if information is ascertained or
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`23-03064-jda Doc 23 Filed 02/22/24 Entered 02/22/24 13:50:08 Page 1 of 17
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`EASTERN DISTRICT OF MICHIGAN
`
`
`
`
`
`
`
`
`Case No. 22-31772-jda
`Chapter 11 proceeding
`Subchapter V
`Hon. Joel D. Applebaum
`
`Adv. No. 23-03064-jda
`
`
`
`
`
`
`
`
`
`v.
`
`
`
`
`
`
`In re:
`
`
`ENERGY DRILLING SERVICES, LLC,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`_________________________________/
`
`ENERGY DRILLING SERVICES, LLC,
`
`
`
`
`
`ENERGY SITE SERVICES, LLC,
`THE MINORITY ALLIANCE GROUP, LLC,
`KAITLYN ADLER, and JEROME BARRY, III
`
`Defendants.
`
`
`
`_________________________________/
`
`
`Plaintiff,
`
`
`
`PLAINTIFF’S FIRST SET OF WRITTEN DISCOVERY REQUESTS TO DEFENDANTS
`
`Plaintiff, Energy Drilling Services, LLC, propounds its First Set of Written Discovery
`
`Requests upon Defendants, Energy Site Services, LLC, The Minority Alliance Group,
`
`LLC, Kaitlyn Adler, and Jerome Barry, III, pursuant to FED. R. CIV. P. 26, 33, 34, and 36,
`
`as incorporated and applicable to this bankruptcy proceeding pursuant to BANKR. R. 7026,
`
`7033, 7034, and 7036, and Local Rules 7026-1 – 4.
`
`INSTRUCTIONS
`
`1.
`
`Please furnish all information, however obtained, that is within your
`
`knowledge, possession, or control, or which may be reasonably ascertained by you.
`
`2.
`
`Please supplement the initial responses to this discovery in writing to
`
`undersigned counsel after service of the responses if information is ascertained or
`
`23-03064-jda Doc 23 Filed 02/22/24 Entered 02/22/24 13:50:08 Page 1 of 17
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`
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`acquired that falls within the scope of these Interrogatories, Requests for Production, and
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`Requests for Admission, hereinafter referred to collectively as “Requests.”
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`3.
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`If you are unable to answer any part of these Requests in full, after
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`exercising due diligence to secure the information necessary to do so, please answer to
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`the extent possible. Please specify that the answer is or may not be complete.
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`4.
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`If you decline to answer any part of these Requests under a claim of
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`privilege or other objection, please respond to the extent not subject to the claimed
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`privilege or objection and indicate the basis for refusing to comply with the Request.
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`5.
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`If any document is withheld under a claim of privilege, furnish a list which
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`identifies each Document for which the privilege is claimed, including the following
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`information:
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`(a)
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`The sender(s);
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`(b)
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`The recipient(s);
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`(c)
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`The date of such Document;
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`(d)
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`The subject matter and length of the Document;
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`(e)
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`Each person who has or has had access to or received a copy of the
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`Document or any portion thereof;
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`(f)
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`The basis on which the privilege is claimed and the facts supporting
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`such claim; and
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`(g)
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`The paragraphs of the discovery to which the Document is
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`responsive.
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`7.
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`If any Documents or tangible things requested were at one time in
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`existence, but are no longer in existence, then so state, specifying for each Document or
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`2
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`tangible thing:
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`(a)
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`Identify the Document by date, author, address and subject matter;
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`(b)
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`The date upon which it ceased to exist;
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`(c)
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`The circumstances under which it ceased to exist;
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`(d)
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`The Identity of all persons having knowledge of the circumstances
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`under which it ceased to exist; and
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`(e)
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`The Identity of all persons having or who had knowledge of the
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`contents thereof.
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`DEFINITIONS
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`1.
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`“You,” and “Your” or “Defendants” means Energy Site Services, LLC, The
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`Minority Alliance Group, LLC, Kaitlyn Adler, and Jerome Barry, III and their subsidiaries,
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`parents and affiliates, corporate predecessors and successors, past or present agents,
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`employees, members, officers, or directors, and all other persons acting on their behalf.
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`2.
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`“EDS” or “Plaintiff” means Energy Drilling Services, LLC, the plaintiff in the
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`above captioned case.
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`3.
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`“Petition Date” means November 29, 2022, the date EDS filed its
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`bankruptcy Petition.
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`4.
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`“Complaint” means the Complaint filed by EDS against Defendants
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`commencing this Adversary Proceeding No. 23-03064-jda (the “Adversary Proceeding”).
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`5.
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`“Answer” means the Answer filed by Defendants in the Adversary
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`Proceeding at DN 7.
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`6.
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`7.
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`“Preference Period” means the one year prior to the Petition Date.
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`“Avoidance Period” means the two years prior to the Petition Date.
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`8.
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`“Transfers” means, collectively, transfers in the aggregate amount of
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`$1,503,875.49, which transfers occurred on or about 11/30/2021, 12/1/2021, 12/2/2021,
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`12/31/2021, 1/7/2022, 1/10/2022, 1/11/2022, 1/14/2022, 1/22/2022, 1/26/2022,
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`1/31/2022, 2/28/2022, 3/1/2022, 4/1/2022, 4/19/2022, 4/22/2022, 4/27/2022, 4/28/2022,
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`4/29/2022, 4/30/2022, 5/1/2022, 5/19/2022, 5/31/2022, 6/7/2022, 6/17/2022, 6/30/2022,
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`7/31/2022, 8/15/2022, 8/26/2022, 8/30/2022, 8/31/2022, 9/8/2022, 9/19/2022, 9/30/2022,
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`10/7/2022, 10/13/2022, 10/21/2022, 10/31/2022, 11/2/2022, and 11/3/2022, each of
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`which is individually a “Transfer.”
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`9.
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`“Proof of Claim” means any and all Proof(s) of Claim filed by Defendants in
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`the main bankruptcy, case number 22-31772-jda.
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`10.
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`“Document” means every writing of every type or description, and every
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`other thing constituting any medium by which, through which, or on which any type of
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`communication, information, or knowledge has been transmitted, recorded or preserved.
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`“Document” also means any copy of a document where such copy is not an identical
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`duplicate of the original. “Document” also includes, without limitation, papers; books;
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`correspondence; telegrams; telex messages; emails; text, instant, or direct messages;
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`memoranda; notes; work papers; spreadsheets; transcripts; minutes; reports; recordings
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`of telephone or other conversations, interviews, conferences or meetings; summaries;
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`analyses; contracts; agreements; journals; logs; statistical records; desk calendars;
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`appointment books; diaries; tax returns; charts; sound recordings; computer printouts;
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`microfilms; photographs; checks; invoices; bills; bookkeeping and accounting records;
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`and financial reports and information.
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`11.
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`“Affiliate,” “Affiliated,” or Affiliation means a person or entity that directly or
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`indirectly, through one or more intermediaries, controls or is controlled by or is under
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`common control with, the referenced entity or person. It also describes a person or entity
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`that directly or indirectly, through one or more intermediaries, controls or is controlled by
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`or is under common control with, the referenced entity or person.
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`12.
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`“Identify”
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`a.
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`When used in reference to a natural person or potential witness,
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`means to state the full name of each person or potential witness to whom the Request
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`applies and his/her present or last known address and telephone number.
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`b.
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`When used in reference to a corporation or entity, means to identify
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`the full name and address of the business.
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`c.
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`When used in reference to a document, means to state the following
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`as to each document:
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`(1) name, title, and date of the document;
`(2) name and address of the author;
`(3) summary of the document, including a description of the type of
`document (e.g., memo, invoice, letter, check, recording);
`(4) name and address of each recipient of the document;
`(5) if the document was, but is no longer, in your possession or control,
`explain the disposition of the document and the name, address, and
`telephone number of the custodian of the document.
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`When used in reference to a fact, means to describe specifically and
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`d.
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`precisely and to state the basis on which Defendant relies for asserting the truth or
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`existence of such facts.
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`e.
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`With respect to a communication, state its date, location, method,
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`purpose and subjects discussed, and identify (as defined above) all persons who were
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`invited to participate and all persons who were present during or participated in the
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`communication.
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`13.
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`“Explain in detail” means to state each fact, circumstance, occurrence or
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`condition concerning the subject of the Request as of the date the Request is answered.
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`14.
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`“Person” shall mean and include a natural person, individual, partnership,
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`firm, corporation or any other kind of business or legal entity or group of persons, and
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`each division, department, or other unit thereof, as well as its agents, representatives or
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`employees.
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`15.
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`The terms “and” and “or” shall be construed either conjunctively or
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`disjunctively as required by the context to bring within the scope of these Requests any
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`information which might be deemed outside their scope by any other construction.
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`16. Wherever appropriate in these Requests, the singular form of a word shall
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`be interpreted as plural.
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`
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`INTERROGATORIES
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`1.
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`Identify the person or persons answering these interrogatories and each
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`person who was consulted, relied upon, or who otherwise constituted a source of
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`information in connection with the preparation of the answers to these interrogatories,
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`listing with respect to each person the number(s) of the interrogatories he or she helped
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`to prepare or which he or she was consulted with, relied upon, or otherwise constituted a
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`source of information.
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`ANSWER:
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`23-03064-jda Doc 23 Filed 02/22/24 Entered 02/22/24 13:50:08 Page 6 of 17
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`2.
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`Identify each person who has knowledge of 1) any facts relevant to the
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`allegations contained in the Complaint and/or 2) any facts relevant to the responses in
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`your Answer and/or 3) any facts relevant to your Affirmative Defenses provide the full
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`name and home and business address of each individual identified.
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`ANSWER:
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`3.
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`Identify and explain in detail all facts known to each of the Defendants
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`supporting, contradicting, or relating to the allegations in the Complaint.
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`ANSWER:
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`4.
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`Identify and explain in detail all facts supporting, contradicting, or relating to
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`the allegations in your Answer, including but not limited to your affirmative defenses.
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`ANSWER:
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`5.
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`Identify any new value (as defined in 11 U.S.C. § 547) you claim was
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`provided to EDS during the Preference Period.
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`ANSWER:
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`6.
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`Explain in detail how Defendants were paid by EDS prior to and during the
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`Preference Period, including the manner in which EDS paid Defendants (i.e. by check,
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`wire, ACH, etc.) and, to the extent that the method of payment differed or changed over
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`time, explain in detail when and why such change occurred.
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`ANSWER:
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`7.
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`Identify all of the details of the transfers which occurred on or about
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`11/30/2021, 12/1/2021, 12/2/2021, 12/31/2021, 1/7/2022, 1/10/2022, 1/11/2022,
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`1/14/2022, 1/22/2022, 1/26/2022, 1/31/2022, 2/28/2022, 3/1/2022, 4/1/2022, 4/19/2022,
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`4/22/2022, 4/27/2022, 4/28/2022, 4/29/2022, 4/30/2022, 5/1/2022, 5/19/2022, 5/31/2022,
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`6/7/2022, 6/17/2022, 6/30/2022, 7/31/2022, 8/15/2022, 8/26/2022, 8/30/2022, 8/31/2022,
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`9/8/2022, 9/19/2022, 9/30/2022, 10/7/2022, 10/13/2022, 10/21/2022, 10/31/2022,
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`11/2/2022, and 11/3/2022, including the method by which payment was made (i.e. check,
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`wire, ACH, etc.), why it was made, which invoice(s) it paid, what persons or entities were
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`involved in preparing the invoices so paid, and any discussions with EDS regarding the
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`Transfers.
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`ANSWER:
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`8.
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`Identify all invoices and bills or other similar documents generated by each
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`and every Defendant in connection with EDS during the three years preceding the Petition
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`Date, including the date of each invoice, the goods or services it related to, and the
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`amount of the amount of the invoice.
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`ANSWER:
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`9.
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`Except for those associated with an invoice identified in your answer to the
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`preceding interrogatory, identify all goods or services which you claim you provided to
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`EDS during the three years preceding the Petition Date, including the date the goods or
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`services were provided, a description of the goods/services, and the charge to EDS.
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`ANSWER:
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`10.
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`Identify any debt you claim is owed by EDS to each and every Defendant
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`which was not identified in your answer to the preceding interrogatories.
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`ANSWER:
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`11.
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`Identify all transfers and payments received by each and every Defendant
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`from EDS during the three years preceding the Petition Date, including the date of each
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`payment, the amount of the payment, and the invoice it was applied to.
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`ANSWER:
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`12.
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`Identify any and all property, including but not limited to intangible assets,
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`of EDS which is in the possession of or otherwise controlled by any of the Defendants.
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`ANSWER:
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`13.
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`Identify any and all property of EDS which was previously in the possession
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`of or otherwise previously controlled by any of the Defendants.
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`ANSWER:
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`14.
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`Identify any accountant that has provided services to any of the Defendants
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`on or after December 2, 2020.
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`ANSWER:
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`15.
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`Identify each contract held by any of the Defendants on or after December
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`2, 2020 which is a contract for provision of goods and/or services in the same industry
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`EDS operated in or a related or similar industry.
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`ANSWER:
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`16.
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`Identify each contract that existed on or after December 2, 2020 which is a
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`contract for provision of goods and/or services in the same industry EDS operated in or
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`a related or similar industry which caused any of the Defendants to receive a direct or
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`indirect benefit, financial or otherwise.
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`ANSWER:
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`17.
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`To the extent not previously identified, identify all work, leads, contacts, and
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`other resources obtained by any of the Defendants on or after December 2, 2020 which
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`relates to the industry EDS operated in or a related or similar industry.
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`ANSWER:
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`18. With respect to the Requests for Admission found below, for every qualified
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`admission or denial, partial or whole, explain in detail the basis for such qualified
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`admission or such denial, identify documents that support, contradict, or relate to such
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`qualified admission or denial, and identify each person who has knowledge of facts that
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`support such qualified admission or denial.
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`ANSWER:
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`STATE OF MICHIGAN
`) SS.
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`COUNTY OF __________ )
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`, being first duly sworn on oath, deposes and states
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`that the foregoing Answers to Interrogatories are true and correct to the best of my
`personal knowledge.
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`____________________________
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`SUBSCRIBED and SWORN to before me this ________ day of ________________,
`2024.
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`NOTARY PUBLIC
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`_
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`REQUESTS FOR PRODUCTION
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`1.
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`Produce all documents identified, relied upon, or referred to in responding
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`to EDS’ Complaint and EDS’ First Set of Written Discovery Requests.
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`RESPONSE:
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`2.
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`Produce all documents supporting, contradicting, or relating to the
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`allegations in your Answer, including but not limited to your affirmative defenses.
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`RESPONSE:
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`3.
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`Produce all documents supporting, contradicting, or relating to the factual
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`basis for each of the statements set forth in your Answer and affirmative defenses.
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`RESPONSE:
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`4.
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`Produce all account statements generated from December 2, 2020 to the
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`present for any financial account in which any Defendant has an interest in.
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`RESPONSE:
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`5.
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`To the extent not previously produced, produce all account statements
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`generated from December 2, 2020 to the present for any financial account which any
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`Defendant transferred any monies received from EDS into.
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`RESPONSE:
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`6.
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`Produce all tax returns filed after December 2, 2020 to the present for any
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`of the Defendants.
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`RESPONSE:
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`7.
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`With respect to all Defendants, produce all documents sent to an
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`accountant after December 2, 2020 and all documents that were used to prepare tax
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`returns filed after December 2, 2020.
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`RESPONSE:
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`8.
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`Produce complete and unfettered access to the “Foundation” database for
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`EDS and all credentials necessary for same.
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`RESPONSE:
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`9.
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`Produce a complete and unaltered copy of the “Foundation” database
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`maintained for each and every Defendant.
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`RESPONSE:
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`10. Produce all agreements and/or contracts between EDS and each and every
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`Defendant.
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`RESPONSE:
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`11. Produce all documents related to the use of EDS’ property by any of the
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`Defendants.
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`RESPONSE:
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`12. Produce all documents related to the invoices identified in your answer to
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`Interrogatory #7.
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`RESPONSE:
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`13. Produce all documents relating to the amounts you claim EDS owes each
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`of the Defendants.
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`RESPONSE:
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`14. Produce all documents relating to any loans extended to EDS.
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`RESPONSE:
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`15. Produce all correspondence or written communications which have passed
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`between Defendants and any of their agents, representatives, officers, employees, or
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`members on the one hand, and any agent, representative, officer, employee, or
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`shareholder of EDS on the other hand.
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`RESPONSE:
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`16. Produce all documents relating to the Transfers.
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`RESPONSE:
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`17. Produce all statements made by any Defendant concerning the subject
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`matter of this lawsuit, whether written or otherwise recorded.
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`RESPONSE:
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`18. Produce all documents concerning or relating to how payments received
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`from EDS were applied to invoices and/or accounts.
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`RESPONSE:
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`19. Produce all documents related to any internal or external review or analysis
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`of Defendants billings to EDS and/or goods/services allegedly provided to EDS.
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`RESPONSE:
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`20. Produce all documents evidencing or relating to new value Defendants
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`claim to have provided to EDS pursuant to 11 U.S.C. § 547.
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`RESPONSE:
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`21. Produce all documents evidencing or relating to Defendants’ affirmative
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`defenses.
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`RESPONSE:
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`22. Produce all documents that you submitted to any government entity,
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`agency, or program with respect to EDS, and/or all documents that you prepared or
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`received to submit to any government entity, agency, or program with respect to EDS.
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`23-03064-jda Doc 23 Filed 02/22/24 Entered 02/22/24 13:50:08 Page 15 of 17
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`15
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`RESPONSE:
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`23. Produce all records obtained from any non-party to this lawsuit that you
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`have requested or received, whether informally or through a subpoena or other legal
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`request, related to the subject matter of this lawsuit.
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`RESPONSE:
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`24. Produce all documents that may be introduced as an exhibit at trial.
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`RESPONSE:
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`25.
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`To the extent not otherwise produced, produce all documents relevant to
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`the subject matter of this Adversary Proceeding.
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`RESPONSE:
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`REQUESTS FOR ADMISSION
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`1.
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`Admit that EDS was insolvent when each of the Transfers occurred.
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`RESPONSE:
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`2.
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`Admit that the Transfers allowed the Defendant receiving the Transfer to
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`recover more than it would have received if 1) the Transfers had not been made and 2)
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`EDS had filed for relief under Chapter 7 of the United States Bankruptcy Code.
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`RESPONSE:
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`23-03064-jda Doc 23 Filed 02/22/24 Entered 02/22/24 13:50:08 Page 16 of 17
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`16
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`3.
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`Admit that the Transfers were not intended to be a contemporaneous
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`exchange for new value.
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`RESPONSE:
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`4.
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`Admit that the Transfers were not made in the ordinary course of business
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`between the Defendant receiving the Transfer and EDS.
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`RESPONSE:
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`5.
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`Admit that the Transfers were not made according to ordinary business
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`terms.
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`RESPONSE:
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`6.
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`Admit that, after the Petition Date, you had possession of or gained
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`possession of property of EDS, including but not limited property referred to as “mats” in
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`EDS’ industry.
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`RESPONSE:
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`Dated: February 22, 2024
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`Respectfully submitted,
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`
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`By: /s/ Zachary R. Tucker
`Zachary R. Tucker (P75263)
`ztucker@winegarden-law.com
`WINEGARDEN HALEY LINDHOLM
`TUCKER & HIMELHOCH, PLC
`G-9460 S. Saginaw Road, Suite A
`Grand Blanc, MI 48439
`(810) 579-3600 / (810) 579-1748 (facsimile)
`Attorneys for Plaintiff
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`23-03064-jda Doc 23 Filed 02/22/24 Entered 02/22/24 13:50:08 Page 17 of 17
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`17
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