BHHS withheld files Broker must provide to Client, if requested, e.g., Equator, MLS.
BHHS custodian only certified the she made accurate copies of the originals provided to her.
BHHS Custodian of Records does not certify accuracy or completeness of the records produced in response to Tobin’s subpoena
Proudfit produced certified, accurate and complete records without subpoena.
Proudfit certified that “311 pages (311 files and 9 folders) are a true, correct and complete copy of any and all documents for (client) The Gordon B. Hansen Trust, dated August 22, 2008, Nona Tobin, Successor Trustee”
