You are on page 1of 6

Of Counsel:

In pro se

NANCI MEEK
3308 Ariba St
Las Vegas NV 89129
Telephone: (760) 413-5660
Petitioner in Pro Se

IN THE CIRCUIT COURT OF THE FIRST CIRCUIT

STATE OF HAWAII

THE MATTER OF ) T. No. 05-1-0101


)
THE ELVIN R MEEK FAMILY ) REQUEST FOR DISCOVERY
TRUST, DATED JUNE 14, 1996 )
AS AMENDED )
)
)
)
__________________________________)

REQUEST FOR DISCOVERY

PLEASE TAKE NOTICE that pursuant to rule 34 of the Hawaii Rules of

Civil Procedure, Petitioner Nanci Meek made two formal Requests for

Production of documents on July 11, 2008 and August 21, 2008 of

Elizabeth Meek, or counsel for Elizabeth Meek or any consultants or

experts (including accountants) retained by Elizabeth Meek or counsel for

Elizabeth Meek. This document shall serve as our third request for

documents per the status conference held on September 17, 2008 in

Judge Hurai’s chambers and as per sanction of Judge Hurai we request the

following be provided prior to the next Status Conference scheduled for

December 1, 2008 at 9:00 a.m. in Judge Hurai’s chambers.

1
As used in this request for production of documents, the term

“documents” includes statements, writings, and recordings of every kind

(mechanical, electronic, typed or written) including but not limited to

letters, correspondence, maps, diagrams, photographs, motion pictures,

memoranda, notes, reports and transcriptions in the possession of,

subject to the control of, or within the knowledge of Elizabeth Meek, or

counsel for Elizabeth Meek or any consultants or experts (including

accountants) retained by Elizabeth Meek or counsel for Elizabeth Meek.

1. Copies of all account statements related to or reflecting any

and all financial transactions included in the Elvin R Meek

Family Trust dated

June 14, 1996, as well as the Elvin R Meek and Elizabeth A. Meek

Living Trust dated January 10, 1992 as amended.

2. Copies of all correspondence and documents relative to the

Union Bancal stock cash out performed in March of 2004 by Mrs

Meek which were part of the Elvin R Meek 1996 Trust and a

statement relative to the transaction.

3. Copies of all correspondence and documents relative to the

Allianz Annuities listed as Assets in the Elvin R Meek 1996 Trust

from October 19, 2003 to the present. Including any and all

correspondence relative to Mrs Meek changing the beneficiary

on each Allianz Annunity to reflect Lola Reklai (Meek),

2
Elizabeth’s daughter from previous marriage and her

granddaughter Merkll Uremakl.

4. Copies of all of the transactions, statements, accounts

receivable, , monies expended for repairs; current and previous

tenants and rental payment history relative to the rental

properties included in the Elvin R Meek 1996 Trust from

October 19 2003 to the present located at the following

addresses

5. Copies of any and all documents relative to fee conveyance

transactions, transferring of title on any and all properties

(inclusive but not limited to the following addresses: 469 Ena

Road #3405 Honolulu Hawaii and 469 Ena Road #3406

Honolulu Hawaii (Parcels 260130020372 and 260130020373);

521 Hahaione #2120J Honolulu Hawaii (Parcel

#390700040431) (c) 445 Seaside Avenue #3317 Honolulu

Hawaii (Parcel #260210260521) from October 19, 2003 to the

present, as well as justifications for selling properties outside of

courts instructions as per Judge Hurai ruling of December 2005.

6. Copies of all credit card statements (including but not limited to

American Express, Discover, Capitol One, Bank of America etc),

under the name Elvin Meek during the period of July 2003 to

July 2007 which would reflect any and all transactions,

purchases and payments.

3
7. Copies of any and all personal and business bank statements

belonging to Elizabeth Meek (Asanuma) and all those relative to

the Elvin R Meek trust 1996 reflecting deposits, CD’s,

withdrawals as well as any and all financial transactions from

the Bank of Hawaii, 1st Hawaiian Bank, Palau Savings Bank,

Bank of America and any and all other financial institutions

(foreign and domestic) from August of 2003 to the present.

8. Copies any and all phone records and statements relative to

cellular and land line telephone accounts under the name Elvin

Meek and/ or Elizabeth Meek, Lola Meek or Elizabeth Asanuma

from July of 2003 to September of 2004.

9. Copies of documents relating to any and all real estate

purchases (foreign and domestic) made by Mrs. Meek from

October 19, 2003 to the present inclusive of all Fee

Conveyances with respect to the Island Colony property at 445

Seaside Ave #3317 Honolulu Hawaii.

10. Copies of receipts and statements relative to any and all

major purchases and records of transactions of same exceeding

$2,500 from October 19, 2003 to the present including but not

limited to automobile purchases (foreign and domestic).

11. Copies of all records and transactions relative to travel

expenses on behalf of Elizabeth Meek, Lola Reklai Meek, and

4
Merkll Delbot from Hawaii to Palau and mainland US from July

2003 to the present and justification of same.

12. Copies of all records and transactions relating to the

Provident Life insurance policy listed on the Schedule D of the

2007 Tax return describing beneficiary distribution prior from

July 2003 to present.

13. Copies of the bill of sale and breakdown of funeral expenses

for Elvin Meek from Oahu Crematory.

14. Copies of any and all statements, costs relative to the

attorney’s fees charged by Robert Jones, Attorney at Law from

July 2003 to present.

15. Copies of any and all statements and costs relative to

Michael Gould Accountant Paso Robles California from July 2003

to present.

16. An accounting and disclosure of whereabouts of my father’s

personal effects such as family pictures, jewelry, childhood

memorabilia having sentimental attachment to myself and my

brother and of which are of no value to Elizabeth Meek or her

daughter Lola Reklai. It should be noted that Elizabeth Meek

and her daughter for reasons known only to them severed

communication with myself and my brother shortly after our

father’s passing. (See Exhibit “A” attached)

DATED: October 25, 2008, Las Vegas Nevada

5
_______________________
Nanci Meek Petitioner
Self Represented

You might also like