Preview
Electronically Filed - ST LOUIS COUNTY - February 02, 2024 - 11:03 AM
IN THE CIRCUIT COURT OF ST. LOUIS COUNTY, MISSOURI
AMERICAN BUILDERS &
CONTRACTORS SUPPLY CO., INC.,
d/b/a ABC Supply Co., Inc.
Plaintiff, Case No. 23SL-CC00632
v.
JK EXTERIORS, LLC Division 12
and
JACOB KAESTNER,
Defendants.
AMENDED APPLICATION FOR EXAMINATION OF JUDGMENT
DEBTOR JK EXTERIORS, LLC
COMES NOW Plaintiff by and through its attorney or record Anthony
Stein, and makes application to the Court for an Order requiring said defendant
JK EXTERIORS, LLC to appear before this Court on March 26, 2024 at 9:30
a.m., to be examined and answer concerning his property.
In support of this application, plaintiffs state that on December 5, 2023,
this court entered a money judgment in favor of Plaintiff and against JK
EXTERIORS, LLC and JACOB KAESTNER in the principal sum of $163,722.95,
plus interest of eighteen percent per annum and costs of the action. As grounds
for this application, plaintiff states:
Electronically Filed - ST LOUIS COUNTY - February 02, 2024 - 11:03 AM
1. Plaintiff has been unable to locate any property of defendant JK
EXTERIORS, LLC through bank garnishment to satisfy part or all of the
Judgment entered herein.
2. Upon information and belief, JK EXTERIORS, LLC has property in
Missouri subject to execution.
3. Plaintiff requests this Court to order defendant/judgment debtor JK
EXTERIORS, LLC to produce the following documents:
a. JK EXTERIORS, LLC’s 2022 and 2023 Federal and
Missouri Income Tax Returns, including all attachments.
b. All account statements for the periods of January 1, 2023 to
the present from all financial institutions, banks, brokerage accounts, brokerage
firms in which the debtor has or had an ownership interest.
c. The name, address and telephone number of each bank that
is currently holding any deposit of JK EXTERIORS, LLC’s money.
d. A copy of the front and back of all checks written to Jacob D.
Kaestner from January 1, 2023 to the present.
e. The name, address and telephone number of each person
that owes JK EXTERIORS, LLC $50.00 or more.
f. JK EXTERIORS, LLC’s business checkbook, including the
check register and last twelve monthly bank statements for each checking
account in an unredacted form.
g. A copy of all deeds for real estate that JK EXTERIORS, LLC
has had an ownership interest from January 1, 2023 to the present.
Electronically Filed - ST LOUIS COUNTY - February 02, 2024 - 11:03 AM
h. A copy of all titles to all vehicles that JACOB KAESTNER
has had an ownership interest in.
i. A copy of JK EXTERIORS, LLC’s financial statements
prepared for any bank or lending institution.
j. A copy of all W2’s and 1099’s that JK EXTERIORS, LLC has
issued to JACOB KAESTNER for calendar years 2022 and 2023.
WHEREFORE, plaintiff prays for an order of this Court requiring the
judgment debtor JK EXTERIORS, LLC to appear before this Court on March 26,
2024 at 9:30 a.m., to undergo an examination under oath, touching said
defendant’s ability and means to satisfy the judgment rendered in favor of plaintiff
and against this defendant.
/s/ Anthony A. Stein
Anthony A. Stein,
KS Bar No. #14774
4310 Madison Ave.
Suite 201
Kansas City, MO 64111
Tel. (816) 753-1500
Fax. (816) 753-1686
anthonystein@att.net
ATTORNEYS FOR PLAINTIFF
Electronically Filed - ST LOUIS COUNTY - February 02, 2024 - 11:03 AM
CERTIFICATE OF DELIVERY
On February 1, 2024, a copy of the foregoing was filed with the Court’s e-
filing system on Case.net. In addition, a hard copy was placed in the United
States mail, postage prepaid and mailed to:
JK EXTERIORS LLC.
A Missouri Limited Liability Company,
(serve its registered agent:
Richard Scott Pecher
1795 Clarkson Road
Suite 150
Chesterfield, MO 63017)
And
JACOB D. KAESTNER
1200 Stone Bluff
Fenton, MO 63026,
/s/ Anthony A. Stein
Preview
Electronically Filed - ST LOUIS COUNTY - February 02, 2024 - 11:03 AM IN THE CIRCUIT COURT OF ST. LOUIS COUNTY, MISSOURI AMERICAN BUILDERS & CONTRACTORS SUPPLY CO., INC., d/b/a ABC Supply Co., Inc. Plaintiff, Case No. 23SL-CC00632 v. JK EXTERIORS, LLC Division 12 and JACOB KAESTNER, Defendants. AMENDED APPLICATION FOR EXAMINATION OF JUDGMENT DEBTOR JK EXTERIORS, LLC COMES NOW Plaintiff by and through its attorney or record Anthony Stein, and makes application to the Court for an Order requiring said defendant JK EXTERIORS, LLC to appear before this Court on March 26, 2024 at 9:30 a.m., to be examined and answer concerning his property. In support of this application, plaintiffs state that on December 5, 2023, this court entered a money judgment in favor of Plaintiff and against JK EXTERIORS, LLC and JACOB KAESTNER in the principal sum of $163,722.95, plus interest of eighteen percent per annum and costs of the action. As grounds for this application, plaintiff states: Electronically Filed - ST LOUIS COUNTY - February 02, 2024 - 11:03 AM 1. Plaintiff has been unable to locate any property of defendant JK EXTERIORS, LLC through bank garnishment to satisfy part or all of the Judgment entered herein. 2. Upon information and belief, JK EXTERIORS, LLC has property in Missouri subject to execution. 3. Plaintiff requests this Court to order defendant/judgment debtor JK EXTERIORS, LLC to produce the following documents: a. JK EXTERIORS, LLC’s 2022 and 2023 Federal and Missouri Income Tax Returns, including all attachments. b. All account statements for the periods of January 1, 2023 to the present from all financial institutions, banks, brokerage accounts, brokerage firms in which the debtor has or had an ownership interest. c. The name, address and telephone number of each bank that is currently holding any deposit of JK EXTERIORS, LLC’s money. d. A copy of the front and back of all checks written to Jacob D. Kaestner from January 1, 2023 to the present. e. The name, address and telephone number of each person that owes JK EXTERIORS, LLC $50.00 or more. f. JK EXTERIORS, LLC’s business checkbook, including the check register and last twelve monthly bank statements for each checking account in an unredacted form. g. A copy of all deeds for real estate that JK EXTERIORS, LLC has had an ownership interest from January 1, 2023 to the present. Electronically Filed - ST LOUIS COUNTY - February 02, 2024 - 11:03 AM h. A copy of all titles to all vehicles that JACOB KAESTNER has had an ownership interest in. i. A copy of JK EXTERIORS, LLC’s financial statements prepared for any bank or lending institution. j. A copy of all W2’s and 1099’s that JK EXTERIORS, LLC has issued to JACOB KAESTNER for calendar years 2022 and 2023. WHEREFORE, plaintiff prays for an order of this Court requiring the judgment debtor JK EXTERIORS, LLC to appear before this Court on March 26, 2024 at 9:30 a.m., to undergo an examination under oath, touching said defendant’s ability and means to satisfy the judgment rendered in favor of plaintiff and against this defendant. /s/ Anthony A. Stein Anthony A. Stein, KS Bar No. #14774 4310 Madison Ave. Suite 201 Kansas City, MO 64111 Tel. (816) 753-1500 Fax. (816) 753-1686 anthonystein@att.net ATTORNEYS FOR PLAINTIFF Electronically Filed - ST LOUIS COUNTY - February 02, 2024 - 11:03 AM CERTIFICATE OF DELIVERY On February 1, 2024, a copy of the foregoing was filed with the Court’s e- filing system on Case.net. In addition, a hard copy was placed in the United States mail, postage prepaid and mailed to: JK EXTERIORS LLC. A Missouri Limited Liability Company, (serve its registered agent: Richard Scott Pecher 1795 Clarkson Road Suite 150 Chesterfield, MO 63017) And JACOB D. KAESTNER 1200 Stone Bluff Fenton, MO 63026, /s/ Anthony A. Stein