Well that won't work because I have no idea where the defendant banks and don't have account numbers. I am entitled to the information because it is relevant to the lawsuit.
Thank you for your follow-up.
I have reviewed the answers and I happen to agree with answers provided. A 'motion to compel' only requires someone to provide records they personally have on-hand (which is why before suit many companies or individuals shred their own documents so as to avoid producing them to others). But going straight to the source, ie the banks, makes more sense--banks would have to respond directly to a subpoena request signed by the judge. Obtaining the numbers to the accounts would need to be done via interrogatories which the parties would have to answer unless they can demonstrate that the question is not relevant, out of scope, or overly broad. What the previous expert suggested is the most certain way of obtaining the information.
I apologize if you felt unsatisfied, but in this instance it would be the same approach I would consider taking on if I were in your position. Please take care.
A deposition is generally done once unless new evidence is found and a formal request is made to courts to request a new deposition. That is done to save costs--depositions can be notoriously expensive both sides, so requesting a new deposition over a few questions could be deemed as inefficient and also as a means of intentionally running up costs. Subpoenas could be requested as time goes on with the finding of new information.
You would need to make them parties--you could potentially attach them as co-defendants and then pursue them for the alleged funds (if any) that they may be holding in their accounts. Then you could subpoena records directly from them and attempt to track and trace the funds and how they were deposited to them.
Hope that helps.
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