So Jay, why have you not filed a motion asking for specific discovery items? You have to name the specific parties you want to depose, send rogs to, and subpoena documents from.
Great. Let's begin.
Who are the specific parties (by name), what are you accusing them of doing that is relevant to the bankruptcy creditors, and what is your evidence to support those allegations, who specifically do you seek to depose and what information do you intend to obtain from them, what specific documents do you wish to subpoena from the specified parties (by name)?
Lemme give you an example:
Request to obtain discovery from STEVEN YEHUDA MOSKOWITZ, former CFO of Spongetech - who is believed to have illegally obtained, concealed, and transferred to third parties presently unknown to Movant, shareholder assets including but not limited to money balances transferred by wire, check, sporting event tickets, and cash. Request the court to authorize you to subpoena all of Moskowitz's personal and business bank account records during the period 2007 to present (including his spouse's bank records), including A&N Enterprises (or whatever the exact name of his dad's business that did "consulting" for SPNG is), records of all sporting event tickets that Moskowitz received either personally or on behalf of Spongetech from 2007 to 2013 and the dispositions of all such tickets, etc. etc. etc.
Get it?
Start with that. Type it out here. I might even help you format it - just for sh_ts and giggles. I will be amused to see you try to file it with the BK court and see the response you get.
Spell it out - names, documents, allegations (specify how this will benefit bankruptcy creditors, explain why you didn't bring this motion during the pendency of the bankruptcy case, and what specific information from each of the named parties you intend to elicit.
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