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FORM 92 (RULE 26(1)) No.

S004040
VANCOUVER REGISTRY

IN THE SUPREME COURT OF BRITISH COLUMBIA

BETWEEN:

TRACY KAPOUSTIN, NICHOLAS KAPOUSTIN BY HIS GUARDIAN


AD LITEM TRACY KAPOUSTIN
AND
MICHAEL KAPOUSTIN

PLAINTIFFS
AND:

THE HONOURABLE MURAVEI RADEV


MINISTER OF FINANCE
IN HIS OFFICIAL CAPACITY
FOR
REPUBLIC OF BULGARIA,
DEFENDANT
and
STEFCHO GEORGIEV, MARIO STOYANOV, EMILIA MITKOVA, KINA DIMITROVA,
IVETA ANADOLSKA, DIMITAR SHACKLE and
DEREK A. DOORNBOS,
INDIVIDUAL DEFENDANTS

Demand For Discovery


Of
Documents

TAKE NOTICE that the Plaintiffs demand you Defendant S. Sgt. Derek A. Doornbos
make discovery of all documents which are or have been in your possession or control
relating to any matter in question in this action within 21 days from delivery of this
demand by providing a list in Form 93.

Plaintiffs rely further on the provisions of Rule 26(8) of the Court that you produce or
make available for copying the following documents, inter alia, referred to in the
Pleadings:

1. All original correspondence from or to Government of Canada, Royal Canadian


Mounted Police and S. Sgt. Derek A. Doornbos from on or about 15 May 1995 to the
present, including but not limited to, inter alia, typed or hand written notes, daily

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diary entries, minutes of meetings, memorandums, directives, letters, agreements,
telephone logs, faxes, telexes, teletype, telephone recordings or as electronic data.

2. All original correspondence to you or from you to any other Defendant in this action
referring to the Plaintiffs personally or their assets, including, inter alia, typed or
hand written notes, daily diary entries, minutes of meetings, memorandums,
directives, letters, agreements, telephone logs, faxes, telexes, teletypes, telephone
recordings or as electronic data.

3. Notes; directives; memos; reports; all private criminal complaints of embezzlement


[Article 203, Criminal Code] as lodged up to and including 28 November 1995 and
any audits in support of the accusation thereof; all private criminal complaints of
misappropriation [Article 206, Criminal Code] as lodged up to and including 12
February 1996 and any audits in support thereof; all private criminal complaints of
fraud [Article 211, Criminal Code] as lodged up to and including the available 12
February 1996 MPPO documents and evidence claimed by the Government of
Bulgaria as proving the existence of, inter alia, 9065 victims of the embezzlement;
3400 statements of claim of witnesses against the Applicant as collected by MPPO by
the aforesaid date; a 382 page computer report listing what the Government
represented as 9000 fraudulent contracts proving Bulgarian citizens “deposited”
12,600,000 USD with the Applicant and further the Government produce a list of the
names of “dead souls” [deceased Bulgarian citizens] claimed by the Government to
the agencies of Interpol as proving a large amount of dirty [criminal] money have
been laundered by Plaintiff Kapoustin.

4. Any other document referred or alluded to in the pleadings setout in the amended
Statement of Claim.

Dated at Vancouver this …………….. day of 2000.

________________________
On behalf of Plaintiffs

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