Jerun Kaipat, General Delivery, Saipan, MP 96950 Telephone No.: 670.989.9747

CNMI COURT Case. 18-0071-cv MOTION TO COMPEL DISCOVERY

Undersigned hereby moves for an order compelling ANTONIO KAIPAT to produce certain documents relating to payments from ASSETS RIGHTFULLY BELONGING TO JERUN KAIPAT AND ERIC KAIPAT. and to produce certain emails. Undersigned incorporates by reference herein the relevant facts and background information as set forth in case papers In support of this Motion, Plaintiff states the following:

A. What the Documents Will Likely Reveal and How that Information is Relevant to the Claims and Defenses in this Case

Undersigned 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). These claims relate principally to unauthorized payments.

B. The Categories of Documents that Need to be Produced

Accordingly, the following categories of documents for the time period 2007-2020 need to be produced so that Undersigned can further support his claims and/or rebut defenses or assertions:

1. Documents which reflect Antonio Kaipat’s role, responsibilities, duties, ownership interest and/or profit participation in any entity.

2. Documents, including drafts of documents, which reflect consulting agreements or arrangements between Antonio Kaipat and any entity.

3. Documents which reflect any consulting services performed by Antonio Kaipat for any entity.

4. Documents which reflect any payments or transfers of funds to or from Antonio Kaipat by any entity.

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

Antonio Kaipat’s counsel has not adequately explained why Antonio Kaipat has kept money that was supposed to go to Jerun Kaipat and Eric Kaipat since 2007

WHEREFORE, undersigneds respectfully requests that the Court order ANTONIO KAIPAT to produce forthwith the documents specified herein and award JERUN KAIPAT all costs and attorney’s fees incurred in connection with this Motion. A proposed order is attached.

Respectfully submitted,

Jerun Kaipat

CNMI COURT Case. 18-0071-cv

ORDER TO SHOW CAUSE

Upon the affidavit of Plaintiff in the above matter, and upon the exhibits annexed thereto,

LET Antonio Kaipat show cause before this Court on, 2019 at 9:30, why an order should not be granted against him pending determination, and for such other and further relief as this Court may deem just and appropriate. It is ORDERED that all requested documents be provided pending determination of the motion brought on by this order to show cause, and it is further ORDERED that personal service of a copy of this order to show cause is deemed sufficient service thereof, and it is further ORDERED that the motion brought on by this order to show cause shall not be orally argued unless notified to the contrary by the Clerk of the Court.

DATED:

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CNMI Court Case Number

BY: Jerun Kaipat & Eric Kaipat, General Delivery, Saipan, MP 96950 Phone 670.7899394

PETITION FOR PROBATE

Petitioners seek probate in common form. They are the sole heirs.

The Decedent, Juan flores Kaipat, died on ________, 2007

The Decedent left no will and was survived by 2 sole heirs: Jerun & Eric Kaipat

The Witnesses have signed an affidavit so that their testimony will not be required for probate.

INVENTORY AND ACCOUNTINGS

Realty:

Personal Property:

Money:

Values of the estate for probate purposes is $

REQUEST FOR RELIEF

All assets and money be released to protectioners.

No administrator or lawyer be involved but if the court requires an administrator the petitioner stipulate it should be the eldest brother

The Petitioners be granted such additional relief as the Court may deem proper.

SIGNATURES: Jerun Kaipat Eric Kaipat

Sworn to and subscribed before me this ____ day of ____________________, 20___.

CNMI COURT

ORDER TO SHOW CAUSE

Upon the affidavit of Plaintiff in the above matter, and upon the exhibits annexed thereto,

LET Antonio Kaipat show cause before this Court on, 2019 at 9:30, why an order should not be granted . .. ..

pending determination, and for such other and further relief as this Court may deem just and appropriate. it is

ORDERED that the above-referenced .. ..

pending determination of the motion brought on by this order to show cause, and it is further ORDERED that personal service of a copy of this order to show cause is deemed sufficient service thereof, and it is further ORDERED that the motion brought on by this order to show cause shall not be orally argued unless notified to the contrary by the Clerk of the Court.

DATED:

https://www.facebook.com/groups/news1501/

https://abvd.shh.mpg.de/austronesian/language.php?id=338

Entries:
ID: Word: Item: Annotation: Cognacy: Loan:
1 hand paay hand/wing/arm 8
1 hand payú-(l) hand/wing/arm 8
1 hand gumʷush wing and hand 9
1 hand gumʷushú-(l) wing and hand of 9
2 left
3 right
4 leg/foot peshe 15
5 to walk fetál around 8
5 to walk (fara)-fetál somewhere, randomly, 8
6 road/path aal path/road/his path 1
6 road/path ala-(l) 1
7 to come
8 to turn sápe- face, turn or proceed (in a direction). Has directional suffix 14
9 to swim áf 7
9 to swim áfe- 7
10 dirty
11 dust
12 skin ghiil 1
12 skin ghili 1
13 back saghúr 12
14 belly uubʷ abdomen 11
14 belly ubʷa-(l) stomach, his a. 11
15 bone shúú 2
16 intestines taa 14
17 liver áse-(l) his liver 1
18 breast útt breast 1
18 breast úttú-(l) her breast 1
19 shoulder aifar shoulder 1
19 shoulder aifár 1
19 shoulder ayúfar carry a load on the shoulder 1
19 shoulder aifara-(l) his shoulder 1
20 to know, be knowledgeable ghule to know / learn 18
20 to know, be knowledgeable ghule-e-(y) to know someone/something 18
21 to think máŋimáŋ be thinking, thought, idea 11
21 to think ághiyágh to think 12
22 to fear me-sagh 1
22 to fear ma-sagh 1
22 to fear me-ságh 1
23 blood tcha 1
23 blood tchaa- 1
24 head úli-(l) his head (respect usage) 1
24 head yúli-(l) his head (respect usage) 1
25 neck úúw 18
25 neck úwa-(l) 18
26 hair ileila- feather/fur/body hair 10
27 nose bʷoot 1, 12
27 nose bʷootú- 1, 12
28 to breathe ŋŋas breathe/breath/sigh 10
28 to breathe ŋasaŋas breathe/breath/sigh 10
29 to sniff, smell
30 mouth aaw 36
30 mouth awa-(l) 36
31 tooth ŋii 30
31 tooth ŋii-(l) 30
32 tongue
33 to laugh ffas to laugh 10
33 to laugh faffas to laugh 10
33 to laugh ghekkáy to giggle/chuckle 11
34 to cry sáŋ cry 1
34 to cry sáŋisáŋ cry 1
35 to vomit mʷmʷus 1
36 to spit óttuf saliva, to spit 19, 55
37 to eat mʷoŋo staple food 8
37 to eat (a)-mʷoŋoo-(w) to feed someone 8
37 to eat aŋi to eat something 1
38 to chew lúúlú to chew on 59
38 to chew lúúlúú-(w) to chew 59
38 to chew ŋúúŋ to chew (as betel nut or sugar cane), 11
39 to cook mʷoot be cooked 19, 82
39 to cook (a)-mʷoot to cook food 19, 82
39 to cook mʷoot 19, 82
39 to cook mʷoota- 19, 82
40 to drink úl 1
40 to drink úlú-mi 1
40 to drink úlú-ma- 1
41 to bite ghey to tear off the husk of coconut or sugarcane with the teeth 38, 73
42 to suck túút to suckle 25
43 ear
44 to hear roŋ 1
44 to hear roŋoroŋ 1
45 eye maas 1
45 eye mesa-(l) 1
46 to see weri to see something 10
46 to see uri to see something 10
47 to yawn (a)-móó-(l) 19
47 to yawn móó-(l-atél) 19
48 to sleep mayúr sleep 1
48 to sleep (ghúla)-mʷmʷey be sleeping deeply 10
49 to lie down wol 1
50 to dream ttal 9
51 to sit móót to sit 18, 101
51 to sit móóte-(tiw) to sit down 18, 101
51 to sit móót-(tiw) to sit down 18, 101
52 to stand úú-(tá) stand up 2
53 person/human being ara-mas 67, 70
53 person/human being are-mas 67, 70
54 man/male mʷáál man/male 1
54 man/male olo- man/male/guy 13
55 woman/female shóó-bʷut 7
55 woman/female liye- 6
55 woman/female liya- 6
56 child layú- 5
56 child sáár 7
56 child sári- 7
57 husband bʷúlú-wa- spouse 16
57 husband shóó-li-imw spouse 39
58 wife bʷúlú-wa- spouse 10
58 wife shóó-li-imw spouse 22
59 mother iil 1
59 mother ila-(l) 1
60 father saam father 1
60 father sema-(l) his father 1
61 house iimʷ 1, 48
61 house imʷa-(l) 1, 48
62 thatch/roof óós thatch 1
63 name iit 66
63 name ita- 66
64 to say
65 rope sáál rope 1
65 rope sálil rope of 1
66 to tie up, fasten féé-tagh set an anchor, tie up a boat 11
67 to sew teete 2
67 to sew tee-yi 2
68 needle
69 to hunt
70 to shoot
71 to stab, pierce ttow to spear something, stab something, give one an injection 13
72 to hit tughu-u-(w) to punch, hit (someone or something) 8, 63
73 to steal mʷósho to steal/be wild/rascally/untamed (of animals) 9
73 to steal púraf to steal 8
73 to steal piraf to steal 8
74 to kill lli to hit 11
75 to die, be dead má die 1
75 to die, be dead máá death 1
76 to live, be alive ma-law 7
76 to live, be alive (a)-ma-lawa 7
77 to scratch kkéét to be scratchy/itchy 11
77 to scratch gherigher to scratch 12
77 to scratch gheregher to scratch 12
77 to scratch gheri to scratch/grate something 12
78 to cut, hack
79 stick/wood ráá- branch 2
79 stick/wood ráá-l branch 2
80 to split tili-ŋi to split or separate (an object) into halves 29
81 sharp kkáŋ 14, 68
82 dull, blunt kkóbʷ 13
83 to work
84 to plant ffót 6
84 to plant fóto-ghi 6
84 to plant fóót 6
85 to choose ffil to choose/select 1
85 to choose fili choose it 1
86 to grow ffóól 8
86 to grow ffóólá-á-li 8
86 to grow ffóóla-a-(y) 8
87 to swell bʷoo 9
87 to swell bʷo 9
87 to swell bʷoobʷo 9
88 to squeeze fei-ŋi to squeeze (something) with the hand. Note: metathesis of vowels 15
89 to hold
90 to dig kkel dig a hole with a digging implement 1
90 to dig kkeli-ŋi dig (a hole) with an implement 1
90 to dig gheli-ŋi dig up (s.t.) 1
91 to buy
92 to open, uncover wáá-si open (the way), make room for (more people) 12
93 to pound, beat pʷpʷoo-li to pound (food) with a mortar and pestle 3
93 to pound, beat úghúúgh do pounding 20, 2
93 to pound, beat úghú-w pound food into paste 20, 2
94 to throw akkesh to throw 14
94 to throw akkásh to throw 14
94 to throw ákkesh to throw 14
94 to throw ashe-(y) to throw s.t. 14
94 to throw ashee-(y) to throw s.t. 14
95 to fall mʷoromʷor to fall (as rain or fruit from tree) 16
96 dog
97 bird
98 egg sóghull 1, 66
98 egg saghull 1, 66
98 egg sóghullu-(l) 1, 66
99 feather ileila- feathers/fur/body hair 30
100 wing
101 to fly yál 13
101 to fly yáliyál 13
102 rat gheesh 16
103 meat/flesh fitúg 10
103 meat/flesh fitugh 10
104 fat/grease
105 tail
106 snake
107 worm (earthworm)
108 louse ghúúw 1
109 mosquito lóómʷ mosquito 1
109 mosquito lómʷo-(l) mosquito of 1
110 spider
111 fish
112 rotten bʷa be rotten on one side (of fruit) 17
112 rotten bʷaa- be rotten on one side (of fruit) 17
113 branch ráá branch 1
113 branch ráá-l branch 1
114 leaf shéé 1
115 root waar roots 2
115 root waara-(l) root of 2
116 flower péé flower, blossom 10
117 fruit uwa fruit 1
117 fruit uwaa-(l) its fruit 1
117 fruit wwa flower 1
118 grass fitil 1
118 grass fetil 1
119 earth/soil pʷpʷel dirt 13
119 earth/soil pʷpʷelú- soil 13
119 earth/soil pʷpʷél be dirty 13
119 earth/soil pʷpʷélú- soiled 13
120 stone faay 1
120 stone faaú 1
120 stone fayú-(l) 1
121 sand ppi 12
122 water shaal water 1
122 water shalú- clear liquid 1
123 to flow bʷu to flow 11
124 sea me-taw 13
124 sea ma-taw 13
124 sea sáát 1
125 salt
126 lake
127 woods/forest walúwal forest, jungle 17
128 sky lááŋ heaven 1
129 moon ma-ram moon, month 7
130 star fúú 1
130 star fúú-(l) 1
131 cloud
132 fog
133 rain úút 1
134 thunder pachch 15, 16
134 thunder pachchú-(l) 15, 16
135 lightning
136 wind ááŋ 1
136 wind yááŋ 1
136 wind yáŋi- 1
137 to blow ughu-u-(w) to blow air on (of a person or wind) 15
138 warm
139 cold ffooy feel cold 11
139 cold ffééy feel cold 11
140 dry mmat be dry/low (of water)/be low tide 11
140 dry mʷór evaporate/dry up 13
140 dry mʷóra-ló evaporate/dry up 13
141 wet tchogh be saturated, soaked, wet 12
142 heavy tchów 9
143 fire (a-ghúú)-áf light a signal fire 1
144 to burn ghú be alight, smolder, be burning 10
145 smoke (bʷa)-at smoky 2
145 smoke (bʷa)-atiyat be smoking lightly 2
146 ash falaŋ wood-burning stove,cooking fire, hibachi, ashes, charcoal, charred wood 8
146 ash mʷó-ósh ashes (as from a cigarete) 9
146 ash (a)-mʷmʷó-ósh ashes (as from a cigarete) 9
147 black shótchól black 8
147 black shól be dark / black all over, 8
148 white
149 red
150 yellow yóleyól light color such as cream, yellow, or tan 9
151 green araw blue 13, 52
151 green arawaraw blue 13, 52
152 small -shigh 81
152 small ghit 80
152 small ghikkit 80
152 small ghitighiit 80
153 big lap 10
153 big llape- 10
154 short mʷoshomʷoosh 12
155 long láálááy be long, tall 13
156 thin má-lifilif thin/flimsy 1
157 thick ma-aliyél 3
157 thick má-áliyél 3
157 thick maaléél 3
158 narrow
159 wide
160 painful, sick metágh painful/hurt 1
160 painful, sick se-mʷaay sick 14
160 painful, sick se-mʷaayú-(l) sick 14
161 shy, ashamed
162 old
163 new ffé be new 1
164 good
165 bad, evil
166 correct, true bʷuŋ be right, correct 12
167 night bʷooŋ 1
167 night bʷoŋi- 1
168 day ráál 6
168 day rááli- 6
169 year
170 when? (i)-lee-t 1, 24
170 when? (i)-lee-ta 1, 24
171 to hide óp to hide oneself from people 5
171 to hide ap to hide oneself from people 5
171 to hide op to hide oneself from people 5
172 to climb téé-(tá) climb 8
172 to climb téé-ghi climb up something 8
173 at i- 1
174 in, inside lló-(l) inside of it 1
175 above
176 below
177 this yeel this close to speaker 1, 33
177 this (i)-yeel this one ( emphatic ) 1, 33
178 that yeel this/that close to speaker 1
178 that (i)-yeel that one (emphatic) 1
178 that (i)-mʷu that one (close to hearer) 11
178 that (i)-mʷuu-l that one (close to hearer, emphatic) 11
179 near a-rap be near 13
179 near akka-rap come closer/approach 13
180 far taaw be far 1
180 far taawu-(ló) be very far 1
181 where? i-fa 3, 48
181 where? iya 37
182 I ŋaaŋ ghaaŋ = analogical back formation 12
182 I ghaaŋ ghaaŋ = analogical back formation 12
183 thou gho- archaic 1
183 thou u- x
183 thou eel 6
184 he/she ii independent pronoun 1
185 we ghiish incl. 1, 42
185 we ay excl. 43
186 you aw 36
186 you áámi 1, 13
186 you -ghámi 1, 13
187 they re- 1, 70
187 they ra- 1, 70
187 they iir 1, 70
188 what? (mee)-t what? 1, 64
188 what? (mee)-ta what? 1, 64
189 who? (i)-yo 9
189 who? (ii)-yo 9
190 other
191 all
192 and me and (with) 2
192 and ŋe and (but) 10
193 if (ŋá)-áre if 7
193 if (ŋ)-áre or (<ŋe are) 7
193 if (ŋ)-are 7
194 how?
195 no, not -se 4
196 to count
197 One eet 1
197 One éét 1
198 Two rúúw 1
198 Two ruwa- 1
198 Two ruwo- 1
198 Two ruwe- 1
199 Three
200 Four fáál 1, 69
201 Five limo-uw 1
201 Five lim-mal 1
201 Five lime-igh 1
201 Five lima- 1
201 Five liim 1
202 Six ool 1
202 Six olo- 1
203 Seven fisu 7
204 Eight wali-igh 3
204 Eight walu-uw 3
204 Eight walú- 3
204 Eight waal 3
205 Nine tiwo- 5
205 Nine tiwa- 5
205 Nine tiiw 5
206 Ten
207 Twenty
208 Fifty
209 One Hundred -bwúghúw 20
210 One Thousand -ŋé-réw 17
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© 2003-2019: Simon J. Greenhill , Robert Blust, & Russell Gray. (0.00663)

Please cite: Greenhill, S.J., Blust. R, & Gray, R.D. (2008). The Austronesian Basic Vocabulary Database: From Bioinformatics to Lexomics. Evolutionary Bioinformatics, 4:271-283.

The Austronesian Basic Vocabulary Database by Greenhill et al. is licensed under a Creative Commons Attribution 4.0 International License.

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