Jerun Kaipat, General Delivery, Saipan, MP 96950

CNMI COURT #18-0071-cv

MOTION TO COMPEL DISCOVERY

I Ask the court transfer to this case18-0462-cv ALL papers filed by me in case 18-0071-cv and note my continued objections to any lawyer or administrator.

I hereby move for an order compelling ANTONIO KAIPAT to produce Documents which reflect

1. Antonio Kaipat’s role in any entity.

2. consulting agreements between Antonio Kaipat and any entity.

3. any consult by Antonio Kaipat for any entity.

4. any payments to or from Antonio Kaipat by any entity.

5. Antonio Kaipat’s bank records, tax returns, financial statements and books of account.

I incorporate by reference herein the relevant facts as set forth in case18-0071-cv

I will set forth claims of Breach of Trust (Count I) Breach of Duty (Count II); Breach of Contract (Count III); Conversion (Count IV); Fraud and Deceit (Count V); and Unjust Enrichment (Count VI).

Antonio Kaipat’s counsel has not explained why Antonio Kaipat kept the money of Jerun Kaipat and Eric Kaipat since 2007

WHEREFORE, I ask the Court order ANTONIO KAIPAT to produce forthwith the documents specified herein and award JERUN KAIPAT all costs and attorney fees. A proposed order is attached.

Respectfully submitted,

Jerun Kaipat

CNMI COURT #18.0462

SHOW CAUSE ORDER

Antonio Kaipat show cause before this Court on DATE….TIME…. why this order should not be granted:

_Antonio Kaipat removed

_ Counsel removed

_ inheritance released