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10. "financial institution" means any of the entities included in the definition contained <br />in 18 U.S.C. § 20 and also means any other entity which holds or has held money on <br />your behalf. <br />11. "financial statement(s)" means any document reflecting the financial condition of <br />the specified person and/or business entity, which definition includes balance sheets, <br />statements of profits and loss, income statements, cash flow statements, and <br />statements of retained earnings. <br />12. "invoice" means any written account or itemized statement containing the items or <br />services provided together with the prices, charges, quantity, amount, or descriptions. <br />The term "invoice" also means any document containing the title "invoice" or any <br />document commonly described as an "invoice". <br />13. "or" means and/or. <br />14. "Petition Date" means August 4, 2015, the date on which the Bankruptcy Case was <br />filed. <br />15. "Receiver" means Ms. Marcie Jaeger, and the firm of Jaeger Kottmeier Associates, <br />LLC (1425 Market Street, Suite 225, Denver Colorado 80202) appointed as Receiver <br />on or about April l5'", 2013 by the District Court of Montezuma County, Colorado <br />for the assets of American Patriot Gold, LLC (f/k/a He -Man LLC) and Red Arrow <br />Gold Corporation. <br />16. "relating to", "regarding", "relative to". or "relate to" means directly or indirectly <br />evidencing, discussing, averring or referring to, referencing, mentioning, noting, <br />discussing, describing, pertaining to, in commotion with, or reflecting any items or <br />matters described after the phrase. <br />17. "Relevant Period" means the time period from January 1", 2013 through the present <br />date. <br />18. "Storage Facility" means that certain warehouse storage facility located at 40575 <br />Hwy.160. Mancos Colorado, Units 54 & 59 utilized by Red Arrow and the Receiver. <br />19. "transfer" has the meaning defined in 11 U.S.C. § 101(54), which includes; <br />(A) the creation of a lien; <br />(B) the retention of title as a security interest; <br />(C) the foreclosure of a debtor's equity of redemption; or <br />(D) each mode, direct or indirect, absolute or conditional, voluntary or <br />involuntary, or disposing or parting with property or an interest in property. <br />The term "transfer" includes transfers in cash and in kind. <br />EXHIBIT B <br />Document Request <br />The definitions and instructions included in Exhibit A apply to each and every request for <br />Documents. Produce the following: <br />1. Any and all communications with the Debtor, or any officer of the Debtor, concerning the <br />Red Arrow Gold Mine and/or the Storage Facility <br />2. Any and all documents reflecting the inventory of all equipment, minerals, core samples <br />or any and all other assets of the Debtor during the Relevant Period. <br />3. Any and all communications with the Receiver or other representative of Maximilian <br />Investors, LLC during the Relevant Period. <br />4. Any and all documents concerning the Red Arrow Gold Mine and the Storage Facility <br />and the property located therein. <br />5. Any and all documents conceming the transfer of assets, core samples, minerals, <br />equipment or materials from the Storage Facility or the Red Arrow Gold Mine <br />6. Any and all documents or communications conceming the Storage Facility. <br />