informatiqii regarding subpoena compliance addresses for

InformatiQii Regarding Subpoena Compliance Addresses For Social Networidng Sites

Social networking sites are not consistent regarding the amount of information at their sites regarding their subpoena compliance polcies, so some site have more information than others,

Facebook

Facebook accepts service at the following address:

Custodian of Records, Facebook, Inc. c/o Corporation Sendees Company 2730 Gateway Oaks Orive, Suite 100 Sacramento, California 9S833

Disclosing Information

Parties to civil litigation may satisfy discovery reqnhements relating to their Facebook accounts by producing and authenticating contents of their accounts and by using Facebook's "Download Your Information" tool, which is accessible tln'oughthe "Accoimt Seltmgs" drop down menu.

If a user camiot access content because he or she disables or deleted Ms or her account, Facebook will, to the extent possible, restore access to allow tlie user to collect and produce the accoimt's content. Facebook preserves user content only m response to a valid law enforcement request. Facebook may provide basic subscriber information (not content) to a party in a civil matter only where: 1) the requested iofonnation is hadispensable to the case and not within the party's possession; and 2) you personally serve a vaUd California or federal subpoena on Facebook. Out-of-state civil subpoenas must be domesticated in Califonaia and personally served on Facebook's registered agent

Pailies seeldng basic subscriber information as set foitli above must specifically identify the account by providhig the emaU address, Facebook user ID (VXD) and vanity U R L (if any) Names, birthdays, locations, and other information are insufHcient to identify a Facebook accormt. UIDs and/or vanity URLs may be found in the uniform resource locator available in a browser displaying the account in question. For example, in the URL http://www.facebook.comyprofile.php?id-12345678910, 12345678910 is the UID.

Facebook charges amandatoiy, non-refundable processing fee of $500.00 per user account. Please enclose payment with your properly served subpoenas. A custodian declaration wiH be included with the return of materials, if any. Notarized declarations cany an additional $100.00 fee.

Prepared for Inns of Court by Sieve Kirson

May 10,2011

Custodian of Records, Facebook, Inc. c/o Corporation Sei-vices Company 2730 Gateway Oalcs Drive, Suite 100 Sacramento, Califoiiua 95833

Re: JElin Wife vs. EldrickBiisband Superior Court: of Fulton County Civil Action File No.: 201 l-CV-123456

Dear Sir or Madam:

Please be advised that om" law fmn represents tlie Defendant, Eldrick Husband, m a lawsuit filed ta the Superior Court of Pulton County. In order to represent our client effectively, it is necessary to examine certain records in yom- possession.

Enclosed please fmd a Subpoena -Duces Tecum/Subpoena for Deposition in the above-referenced matter requiring a representative of Facebook.com to appear for a deposition and bring the requested doctunents with them at the time and place mdicated. Also enclosed is a Notice of Taidng Deposition on Non-Party Facebook, Ino., and a check in the amount of $35.00.

It may be possible for tlie representative of Facebook.com to provide copies of the requested documents in lieu of appearance at the deposition. However, please do not send the documents without my prior consent. Once you receive the subpoena and locate the requested documents, please caE us, and we wiU ask opposing counsel i f she has any objection to yoin-producing the documents prior to the scheduled deposition date in lieu of the scheduled deposition. Please dkect all inquhies to my attention. If opposing counsel has no objection, you may provide a copy of all responsive documents to opposing counsel and me prior to the date of deposition. Should you elect to produce documents m lieu of your deposition, you must execute and return the Response Affidavit verifying that the documents are complete and accurate.

Prepared for Inns of Court by Steve Kirson

Facebook, Inc. May 10,2011 Page 2

Please call me i f tlie production charges -will exceed $35.00.

Sincerely,

Paralegal to Divorce Attorney

Enclosure(s) As stated above

-2-


EliBWife,

Plaintiff,

Vs.

Eldrick Husband,

Defendant.

STATE OF GEORGIA

ACTION

NO. 2011-CV-123456

NOTICE OF T A K M G DEPOSTTION OF NON-PARTy E A C E B O Q K . C O M

E L I N WIFE, Plaintiff By and tin'ougli her counsel of record: A. Scratch Golfer, Esq. Sandtrap & Fan-way, L L C One Overpriced Tower, Suite 100 555 MulHgau Road, N E Atlanta, Georgia 30305

Please talce notice that commenekig at 10:00 a.ni. on M y 4, 2011, Defendant, through Ins

counsel, will talce the deposition upon oral examination of a representative of FACEBOOIC, INC.,

pm-suant to O.C.G.A. § 9-11-30. The deposition will be held before a person duly authorized by

law to administer oaths and talce deposition at the offices of Sacramento Deposition Reporters, 350

University Avenue, Suite 270, Sacramento, Califoi-nia 95825. The deposition will be talcen for

trial and discovery purposes and any and all uses allowed by the Georgia Civil Practice Act.

Said deposition shall then be transcribed by stenogi-aphic means. Defendant shall retahi the

stenogi-apher.


CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I have iMs date seived opposmg coimsel in the foregoing matter

with a t-ue and conect copy of NOTICE OF TAKING DEPOSITION OF NON-PARTY

FACEBOOK, m C , by deposithig a copy of same mto the United States mail to PlahitifPs counsel

of record as follows:

A. Scratch Golfer, Esq. Sandtrap & Fairway, LLC

One Overpriced Tower, Suite 100 555 Mulhgan Road, NE Atlanta, Georgia 30305

Tliis day ofMay, 2011.

FAICENAME, PSEUDONYM & NONDEPLUME, P.C.

Big Office Buildhrg 4321 Peachti-ee Road, N.E. Aflauta, Georgia 30326 (404) 5554212 Office (770) 555-1213 Facsmaile

By: , Attorney for Defendant

Prepared for Inns of Court by Steve Kirson -3-

E X H I B I T " A "

Al l documents and records related to an online account possibly appearing or identified in

your records as user name "[email protected]", or any other email address established

by Ehn W e for fire period of tune ti-om Jaauaiy 1, 2008 to the present, created by Elin Wife on

www.facebQok.com or any otlier mternet site, chat room, blog, emaU account, or other onhne

account, iucludrng the following:

1. Copies of all profiles, biographies, summaries, descriptions, established by Ehn Wife, Social Secuiity Number ,Date of Birth: at anytime;

2. Copies of all messages and other connnunication made to or received by Elin Wife, Social Security Number , Date of Bnth: „ushig the www.facebook.com or any other internet website operated by FACEBOOK, INC.;

3. Copies of documents regardmg all forms of payment made by Elhi Wife, Social Secmity Number , Date of Birth: for use of the www.facebook.coin or any other internet web site operated by FACEBOOK, INC.;

4. Copies of documents or tangible items showing the dates of Ehn Wife's, Social Security Number , Date of Bhth: access to and use' of the www.facebook.com or any other internet web site operated by FACEBOOK, INC.;

5. Copies of documents showmg all www.facebook.com members or other persons accessing the www.facebook.CQm or any other internet web site operated by FACEBOOK.ESfC, who have mitiated coiumunication with Elin Wife, Social Security Number ^, Date of Birth: or witli whom E l k Wife has uiitiated communication;

6. Copies of docmnents showkig the content of all communication, hacluding emails, instant messages and text messages made by or to Efin Wife, Social Secmity Number

, Date of Bhth: usmg the -www.facebook.com or any other mternet web site operated by FACEBOOK, INC.; and

7. Copies of all questionnaires, profiles or other on Ime documents completed by Elhi Wife, Social Security Nmnber , Date of Bhth: in order to access or use the www.facebook.CQm or any otlier internet web site operated by FACEBOOK, INC.

Prepared for Inns of Court by Steve Kirson -4-

T H E

STATE OF G E O R G U F A M I L Y DTS^SION

Elin Wife,

Plaintiff,

Vs.

Eldrick Husband,

CIVIL ACTION

F I L E NO. 2011-CV~1234;

Defendant,

I ^STONSE AEFIDAVTT OF NON-PARTY

FROM: FACEBOOK, INC.

COMES NOW, , and responds to Defendant's Notice of Talmg Deposition of Non-Party and Subpoena sei-ved pursuant to Section 45 of the Civil Practice Act as follows:

Please indicate the appropriate response below:

( ) Copies of the requested materials have been attached. ( ) The materials requested wHl be produced at the designated address. ( ) The materials requested do not exist.

AFFIDAVIT Personally came before me, the undersigned officer, duly authorized to administer oaths,

who, upon being duly sworn, states that (s)he is the custodian of these records and that the copies attached hereto are true and correct and that there are

pages that have been attached and constitute the enthe file materials requested.

Tlris day of ,2011.

Sworn to and subscribed before me this day of , 2011.

Notary Public My commission expires:.


MySpace

Subpoenas may be served at the following address:

Custodian of Records tor MySpace.com 2121 Avenue of tlie Stars, Suite 700 Los Angeles, C A 90067

MySpace will only accept subpoenas fi'om out of state civil litigants if they have properly domesticated tlrough a California coiut.

'"^i' The representative answermg the MySpaoe mfoimation number, 888-309-1311 hi April 2011 reported that civil subpoenas could be faxed to: (310) 356-3485, or emailed to: [email protected]. This information is un-tested and uu-coii'oborated.

Please note that MySpace requhes specific information hi order to comply with yom- legal request. Providmg only the user's fnst and last names or dates of burth is not srrfficieiit to identity the user's profile. MySpace requhes that you provide the user's unique friend ID number or url. The fiiend ID number is located in the url Hue. For example, wilHn the ml http://www.mvspace.coin/index.chii?fus6action^iser.viewFrofile&friendID==622

1&Mvtokeirf0050518161358, tiie friend ID is 6221.

Linkedlii

LinkedIn accepts service at the following address:

Linkedln Corporation A T T N : Legal Departmeni-2029 Stierlin Court Mountain View, C A 94043

Linlcedlii Privacy Policy re: Comphance With Legal Process:

It is possible that we may need to disclose personal information, profde information and/or mformation about youi- activities as a Lmlcedin User when _ reqim-ed by subpoena or otlier legal process, or i f Linlcedin has a good faith belief that disclosm-e is necessary to (a) hivestigate, prevent or take action regardmg suspected or actual illegal activities or to assist government enforcement agencies; (b) to enforce the User Agi'eement, to hivestigate and defend om'selves agamst any ilmd paily clahns or allegations, or to protect flie secmity or integiity of our site; and/or (c) to exerci.se or protect the riglits, property or personal safety of LinkedIn, our Users, employees, or others.

Linlcedin Privacy Policy, paragi-aph 2.K.


Twitter

Twitter directs subpoenas ffom non-law enforcement agencies to: '

Twitter, Inc. c/o Trust and Safety 795 Folsom Sti-eet, Suite 600 San Francisco, C A 94107

Twitter, Inc.'s help center states that Twitter, Inc. is located m San Francisco, Califoixda and will only respond in compliance with U.S. law to valid legal process. By emphasizing theh location, attorneys should go tb:ough the process of domesticathig then- subpoenas m Califoniia. Twitter's site also provides that Twitter accepts legal process firom law enforcement agencies deHvered by mail or fax, but that acceptance of legal process by iiiese means is for convenience only and does not waive any objections, mcluding the lack of jurisdiction or proper sei-vice. Your request should include the U R L of the Twitter profde in question (eg., http://twitter.com/safety or ©safety), and details about what specific ioformation is requested.

Twitter conducts most coixespondence via email, so PLEASE INCLUDE A V A L I D EMAIL ADDRESS so Twitter may contact you. To contact Twitter, email: lawenforcement® twitter.com. You can fax Twitter, attention Trust & Safety, at 1-415-222-9958

Twitter's website emphasizes law enforcement rather than civil subpoenas, and provides:

Only email from law enforcement domains wil l be accepted. A l l others wi l l be disregarded.

YouTube

You can contact YouTube at the address below;

YouTube, L L C Custodian of Records 901 Cherry Ave. San Bruno, C A 94066

Phone: (650) 253-0000 Fax: (650)253-0001

Note that YouTube is a subsidiary of Google, Inc.


G o o g l e

You can direct a subpoena domesticated in California to:

Google, Inc. Custodian of Records 1600 Amphitbeater Pailcway Mountain View, CA 94043

Phone: (650) 253-0000 Fax: (650)253-0001

Note same contact numbers as YouTube because Google is the parent company of YouTube.

A O L

Though A O L is not, strictly speaking, a social networldng site, many internet users during AOL's glory years may still maintain A O L email accounts. The foUowmg uifoi-mation about sei-vice of a subpoena upon A O L was found at AOL ' s website:

A O L , its records, and its Custodian of Records are located in Loudoun County, Vi-i-ginia. AOL's headquarters are in the State of New York. A O L accepts subpoenas that are properly issued pursuant to Federal Rule of Civil Procedure 45 and apphcable state laws. For all properly issued subpoenas for account holder uiformation or hiEbrmation sufficient to identify an account holder, service should be made upon AOL's registered agent:

Corporation Sei-vice Company 11 South 12th Street Post Office Box 1463 Richmond, Virginia 23218

Upon receipt of a vahd subpoena, it is AOL ' s policy to promptly send notification to the accoimt holder whose iofoimation is sought, hi order to provide an account holder time to respond to fiie subpoena, A O L will not produce the subpoenaed account holder information until ten business days after the account holder has been notified by AOL. A O L will issue uivoices for tlie costs associated with subpoena compliance. A O L charges $125.00 per hour for research and administrative costs, $14.00 for oveiiiight mail, and 25 cents per copy. AOL will hivoice the subpoenaing party prior to production, and payment must be made prior to the production of the subpoenaed infoitnation.

Prepared for Inns of Court by Stsve Kirson

The subpoenas on the followhig pages, exceipted h-om United States District Court documents, filed electronically, were issued in a non-domestic relations civil case in the Sony Computer Entertainment's anti-phacy Play Station 3 lawsuit against hacker GeoHot (George Hotz). The Htigation was reported to have settled in April, 2011.

The subpoenas are provided for theh examples of docmnent request language and tenxiinology (ISfote that these subpoenas were seeldng to identify all visitors to the Defendant's blog and website.)

Source: http://www.wh-ed.cornyimagesj3logs/thi-eatleveiy2011/03/speroruling.pdf

Prepared for Inmof Court by Steve Kirson

Case3:11"CV-00167-S! Document8B-1 Fi!eci03/01/11 Page8 of 31

A.0 BEB (Rev, 01/09) Subpoena to Produce Documents, Informatioii, or Objects or lo Permit Inspection of Premises

UNITED STATES DISTRICT COURT for tlie

Northern District of California

Sony Computer Entertainment America LLC

Plaintiff )

V, ) Civil Action No. C~11-00167 Si

George Hotz; Hector Martin Cantero; Sven Peter; ) and Does 1 through 100 ) (if ^clion is pending b another district, states where:

Defendant

S U B P O E N A TO P R O D U C E D O C U M E N T S , I N E O R M A T I O N , O R OB'JECTS OR TO P E R M I T INSPECTION OF P R E M I S E S

To: Twitter, Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94017

1^Production: Y O U A R E C O M M A N D E D to produce at ths time, date, and place set forth below the following

documen-ts, electi-omcally stored information, or objects, and permit thek inspection, copying, testing, or samphng of the

material: See Attachment A

Place: Kllpatrick Townsend & Stockton LLP Two Embarcadero Center, 8th Floor San Francisco, CA 94111

Date and Time:

03/16/2011 10:00

• Inspection of Premises: Y O U A R E C O M M A N D E D to penuit entry onto the designated premises, land, or other property possessed or controlled by you at the time, date, and location set fortli below, so that the requesting party may inspect, measure, survey, photograph, test, or samplethe tJioperty or any designated object or operation on it.

Place; Date and Time;

The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule

45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, ai-e

attached.

Data:

CLERK OF COURT OR

Signature of Clerk or Deputy Clerk Attorney's signature

The name, address, e-mail, and telephone number of the attorney representing (name of party)

Sony Computer Entertainment America Li!c , who issues or requests this subpoena, are:

Holly Gaudreau, Esq., Kllpatrick Townsend & Stockton LLP, Two Embarcadero Center, 8th Floor, San Francisco, California 94111; E-mail: [email protected]; Telephone: 415-57B-0200

Case3:11-cv~00167-S! Document88-1 Fi!ed03/01/11 Page9 of 31

AO BKB iP-W. 01/09) SubpQEua la Produce DDcumEnls, Inforraalion, or Objects or to Permit Inspection of PremiscB [FaBB 2)

Civil Action No. C-11-0ai67Sl

P R O O F O F S E R V I C E

(This section should not be filed with the court unless required by Fed R. Qiv. P. 45.)

Ttlis subpoena for (namB of individual and tide, if any) —

was received by me on (dale) •

• I personally served tlie subpoena on the individual Bt-(place) ^

on (dots) ; or

• 1 left the subpoena at the individual's residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

Qn(d^) ,and mailed a copy to the individual's last known address; or

• 1 served the subpoena to (name of individual) ^ •'

designated by law to accept service of process on behalf of (name of organization) _

on (date) ; or

• I returned the subpoena unexecuted because '

O other (4/7fic/ftJ;

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the wititess fees for one day' s attendance, and the mileage allowed by law, in the amount of

iVly fees are $ for travel and % for services, for a total of $ O.QQ

I declm-e under penalty of perjuiy that this information is true.

Date: Seiyer's signature

Printed name and liile

Server's address

Additional mformation regarding attempted service, etc:

Case3:11-cv-00167-SI Document8B-1 Filed03/01/11 Page10of31

AO E8B (R-ev. 01/09} Subpoena to Produce DDcuments, Infoimation, or Objects or to Fsmiit Inspection of Premises (PagB 3)

Federal Rule of Civ i l Procedure 45 (c), (d), and (e) (Effective 12/1/07)

(c) Protecting a Person Subject to a Subpoena. (i) Avoiding Undue Burden or Expense; Sanctions. A pariy or

attorney responsible for issuing and serving a subpoena must talce reasonable steps to avoid imposing undue burden ov expense on person subject to the subpoena. The issuing court must enforce this duty and impose an appropriate sanction — which may include lost earnings and reasDnable attorney's fees on a party or tittorney who fails to comply.

(2) Command to Produce Materials or Permit Inspection, (A) Appearance Not Required. A person commanded to produce

documents, eleolronically stored information, or tangible tilings, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.

(B) Objections, A person commaiided to produce documents or tangible tilings or to permit inspection may serve on the party or attorney designated In the subpoena a written obj ection lo inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing elBotronlcally stored information in the form ov forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after tlie subpoena is served. If an objection Is made, the following rules apply:

(i) At any time, on notice to the commanded person, tlie serving party may move the issuing court for an order compelling production or inspection.

(ii) Tliese acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's •fificer fi-om significant expense resulting from compliance. (3) Quashing or Modifyittg a Subpoena.

(A) When Required. On timely motion, the issuing court must quash or modify a subpoena that;

(i) fails to Edlow a reasonable time to comply; (ii) requhes a person who is neither a paity nor a party's officer

to travel more than IQO miles fiom where that person resides, is eniptoyed, or regularly transacts business in person—except that, subject to Rule 45Cc)C3)CB)(iii), the person may be commanded to attend a trial by fraveling from any such place within tlie state where the trial is held;

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden. (B) iVhen Permitted. To protect a person subject to or affected by

a subpoena, the issuing court may, on motion, quash or modify the subpoena if it requires:

(i) discloaijig a trade secret or otlier confidential research, development, or cominercial information;

(ii) disclosing an unretmned expert's opinion or information that does not describe specific occurrences in dispute and resuhs fi:om the expert's study that was not requested by aparty; or

(iii) aperson who is neither a party nor a party's officer to incur substantial eKpense to travel more than 100 miles to attend trial.

(C) Specifying Conditions as an Alternative. In the circumstances described InRiiie 45Cc)(3)CB),the court may, instead of qtiashing oi: modifying a subpoena, order appearance or production under specified conditions if the serving party:

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that die subpoenaed person will be reasonably compensated.

(d) Duties hi Responding to 5 Subpoena. (1) Producing Documents or Electronically Stored Information.

These procedures apply to producing documents or electronically stored information:

(A) Documents. A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to tlie categories in the demand.

(B) Fonnfor Producing Electronically Stored Information Mot Specified. If asubpoenadoes not specify a form for producing electronically stored infomaation, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.

(C) Electronically Stored Information Produced in Only One Form. The person responding need not produce the same electronically stored uiformation in more than one form.

(D) Inaccessible Electronically Stored Information. Tlie person responding need not provide discovery of electronically stored infoi-mation from sources that die person identifies as not reasonably accessible because of undue burden or cost On motion to compel discovery or for a protectiva order, the person respondmg must show that die information is not reasonably accessibie because of undue burden or cost. If that showing is made, tlie court may nonedieless order discovery &ora such sources iffhe requesting parly shows good cause, considering the hmitations of Rule 26(b)(2)CC). The court may speci:^ conditions for the discovery. (2) Claiming Privilege or Protection. (A) Information- Witiiheld. A person withholding subpoenaed

information under a claim that it is privileged or subject to protection as trial-preparation material must;

(i) expressly raalcethe claim; and (ii) describe the nature ofthewithlield documents,

communications, or tangible thmgs in a manner that, without revealing information itself privileged or protected, ^viU enable the parties to assess the claim.

(B) Iriformatian Froduced. If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparationmaterial, the person making tlie claim may notify any party that received the information of the claim and the basis for it. After being notified, a paity must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim ia resolved; must talce reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present tire jnfomiation to the court under seal for a determinadon of the claim. The person who produced the information must preserve the information until the claim is resolved.

(e) Contempt The issuing court may hold m contempt a person who, having been served, fails without adequate excuse to obey the subpoena. A nonparty's failure to obey must be excused if the subpoena purports to requhe the nonparty to attend or produce at a place outside the limits of Rule 45(c)(3}(A)Cii).

Case3:11-cv-00167-Sl Document88-1 Filed03/01/11 Page11 of 31

INSTRUCTIONS

1. Twitter, Inc. Is directed to furnish all documents, including electronically

stored Information, in its possession, custody or control.

2. A s to any portion of any request that refers to documents that Twitter, Inc.

is aware of which were at one time within its possession, custody or control, hut which

are not now within or subject to its possession, custody or control, Twitter, Inc. Is

directed to identify such documents in a manner sufficient to describe such documents

for the purpose of preparing and serving a proper subpoena duces tecum and to give

the name, telephone number, and address of the person last I<nown by Twitter, Inc. to

have been in possession, custody or control of such documents.

3. If any document requested by this subpoena has been destroyed, set forth

the contents of the document, the date of its destruction, and the name of the person

who authorized its destruction.

Case3:11-cv~00167-SI Document88"1 Filed03/01/11 Page12 of 31

noCUMEMT REQUESTS

1 All information and documents related to the use of your service(s) to - • <

register, create; maintain and/or use the Twitter account associated with Twitter

Username "geohot", formerly iocated at <http;//twitter.com/geohot>.

2. Documents reproducing all content - including but not limited to all

"Tweets" - posted and/or published by the Twitter account identified in Request No. 1

above from January 1, 2009 until the present, including but not limited to all content

posted and/or published at <http://iwitter.com/geohot> from January 1,2009 until the

present

3, Documents sufficient to Identify all names, addresses, and telephone

numbers associated with the Twitter account identified in Request No, 1 above.

. 4. Documents reproducing all server logs, IP address logs, account

information, account access records, and application or registration forms related to the

Twitter account identified in Request No. 1 above.

5. Documents reproducing all e-mails, correspondence, or other material

between you and the owner or user of the Twitter account identified in Request No. 1

above.

6. Ali documents related to any service that you have provided to the owner

or user of the Twitter account identified In Request No. 1 above at any time, whether

physically or electronically stored.

63137276 V2

Case3:11-cv~00167-SI DocumentSB-l Fiied03/01/11 Page14of 31

AO SBB (Rev. 0!/Q9) Subpoena lo Produce Documents, Informotion, or Objects or to Penuit Inspection of Premises

UNITED STATES DISTRICT COURT for the

Northern Dishrict of California

Sony Computer Entertainment America LLC Phindjf •

V. George Hofz; Hector Martin Cantero; Sven Peter;

and Does 1 through 1D0 Defendant

Civil Action No. C-11-00167S!

(If tlie action is pending in anotlier district, state where:

S U B P O E N A TO P R O D U C E D O C U M E N T S , I N F O R M A T I O N , O R O B J E C T S O R T O P E R M I T INSPECTION OE P R E M I S E S

To: Google, Inc., Attn: Google Legal Support, 1600 Amphlthsalre Parkway, Mountain View, C A 94043

dProduction: Y O U A R E C O M M A N D E D to produce at the time, date, and place set fortli helow the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: See Attachment A

Place: Kilpairick Townsend & Stockton LLP Two Embarcadero Center, 8th Floor San Francisco. CA 94111

Date and Time:

03/16/2011 10:00

D Inspection of Premises: Y O U A R E C O M M A N D E D to permit entry onto the designated premises, laiid, or other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting pai-ty may inspect, measure, .survey, photograpli, test, or sample the property or any designated object or operation on i t

Place; Date and Tuiie:

The provisions of Fed. R, Civ. P. 45(c}, relating to your protection as a person subject to a subpoena, and Riale 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, ai-e attached.

Date:'

CLEBKOF COURT OR

Signature ofClailc or Deputy Clerk Attorney's signature

The name, address, e-mail, and telephone number of the attorney representing (name of party)

Sony Computer Entertainment America LLC , who issues or requests this subpoena, are:

Holly Gaudreau, Esq., Kllpatrick Townsend & Stockton LLP, Two Embarcadero Center, 8th Floor, San Francisco, California 94111; E-ma!U [email protected]; Telephone: 415-576-0200

Case3:11-cv-00167-S! Document88-1 Filed03/01/11 Page15 of 31

AO SEB (Rev. 01/09) Subpoena ia Produce Documents, InfDrraation, or Objects or to Permit Inspection of Premises (Page 2) ^

Civil ActionNo. C-11-00167 SI

P R O O F O^- SERVICE

(This section should not be filed with the court unless required by Fed. R. Qv. P. 45.)

This subpoena foxfimme of individual anddtie, if any)

was received by rae omfdaie) •

• 1 personally served the subpoena on the individual at (place)

on (dale) ; or

• 1 left the subpoena at the mdividuaPs residence or usual place of abode with (name)


oii (date) . , and mailed a copy to the individuars last laiown address; or

• I served the subpoena to (name of individual) ^ _ , ' ^^"^

designated by law to accept service of process on behalf of (mme of organization)

on (date) ; or

D I returned the subpoena unexecuted because • '

• other (specify):

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in tlie amount of

Myfeesare$ for h-avel and $ for services, for atotal of $ Q.OQ

I declare under penalty of perjury that this infoimation is trae.

Date: Server's signature

Printed name and lille

Server's address

Additional information regarding attempted service, etc:

Case3:11-cv-00167-Sl DocumentB8-1 FiledO3/01/11 Page16of 31

AO BEB (Rev. 01/09) Subpoena to Produce DocumEnls. InformBtim. or Objects or to Permit Inspectioti of Premises (Page 3)

federal Rule of Civi l Procedure 45 (c), (d), and (e) (Effective 12/1/07)

(c) Protecting a Person Subject to a Subpoena. {1) Avoiding Uttdue Siirden or Expense; Sanctions. A-pody or

attorney responsible for issuing and serving a subpoena must talce reasonable steps to avoid impoeing undue burden or expense on person subject to die subpoena, The issuing court must Enforce this duty and impose an appropriate sanction—which may include lost earnings and reasonable attorney's fees — on a party or attorney wiio foils to comply.

(2) Command to Produce Materials or Permii Inspection. (A) Appearance Not Required. A person conunandedto produce

documents, electronically stored information, orlangibiethings, or to permit tiie inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.

(B) Objections. A person commanded to produce documents or tangible things or to permit inspection may serve on tlie party or attorney designated in the subpoena a written objection to inspectLng, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing elecfronically .stored information in tlie form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoenais served. If an objection is made, &e followhig rules apply;

(i) At any time, on notice to die commanded person, the serving party may move tlie issuing court for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither aparty nor a party's officer fiom significant expense resulting from compliance.

(3) Quashing or Modifying a Subpoena. (A) When Required. On timely motion, the issuing court must

quash or raodif / a subpoena that: (i). fails to allow a reasonable time to comply; (li) requires a person who is neither a parly nor a parly's officer

to travel more than 100 miles iiom where tliat person resides, Is employed, or regularly traiisacts business in person—except that, subject to Rule 45Cc){3)(B)(iii), tire person may be conmianded to attend a trial by traveling from any such place within the state where the trial is held;


(iv) subjects aperson to undue burden. (B) When Permitted. To protect aperson subject to or affected by

a subpoena, the issuing court may, on motion, quaah or modify tlie subpoena if it requires:

(i) disclosing a trade secret or other confidenliai research, development, or commercial mformation;

(li) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party; or

(iii) a person who is neither aparty nor a party's office:-to incur substantial expense to travel more than 100 miles to attend trial.

(C) Specifying CoMitions as an Alternative. In the circumstances described in Rule 45(c)C3)tB), tiie court may, mstead of quashing or modifying a subpoena, order appearance or production under specified condilloDs if the serving party:

(i) shows a substantial need for tiie testimony or raalerial that cannot be otherwise met without undue hai'dship; and

(li) ensures that the subpoenaed person will be reasonably compensated.

(d) Duties in Responding to a Subpoena. il) Producing Documents or Blecivonically Stored Information.

TliesQ procedures apply to producing documents or electronically stored infomaation:

(A) Documents. A person responding to a subpoena to produce documents must produce them as they are Icept in the ordinary course of business or must organize and label them to correspond to die categories In the demand.

(B) Form for Producing Electronically Stored Information Hot Specified. If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.

(C) Electronically Stored Information Produced in Only One Form. The person responding need not produce the same electronically stored information in more than one form.

(D) Inaccessible Electronically Stored Information. The person responding need not provide discovery of electi-onioaliy stored information from sources that the person Identifies as not reasonably accessible because of undue burden or cost On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, die court may nonetheless order discovery from such sources if the requesfing party shows good cause, considering the Hraitadons of Rule 26(b)(2)(C). The court may specify condhions for the discovery. (2) Claiming Privilege or Proteciion. \K) Information Jfi/AfieW. A person witliholding subpoenaed

information under a claim that it is privileged or subject to protection as trial-preparation material must:

(i) expressly make the claim; and (ii) describe the nature of the withheld documents,

communications, or tangible things in a manner that, without revealing mformation Uself privileged or protected, will enable the pardcs to assess the claim. (B) Information Produced. If information produced in response to a

subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person malcing the claim may noti^ any party tliat received the information of tlie claim and tlie basis for it. After being notified, a parly must promptly return, sequester, or destroy tiie specified information and any copies it has; must not use or disclose the information until the clahn. is resolved; must take reasonable steps to retrieve the information if the party disclosed h before being notified; andmay promptly present the information to the court under seal for a detemdnallon of the claim. The person who produced the Informadon must preserve the Information until the claim is resolved.

(e) Contempt. The issuing court may hold in contempt a person who, having been served, fails widiout adequate excuse to obey the subpoena. A nonparty's fuilure to obey must be excused if the subpoena purports to require the nonparty to attend or produce at a place Dutsidethe limits of Rule 45(c)(3)(A)(ii).

Case3:11~cv-00167-S] Document88-1 Filed03/01/11 Page17 of 31

ATTACHiV IENTA

INSTRUCTIONS

1. Google, Inc. is directed to furnish all documents, including electronically

stored information, in its possession, custody or control

2. As to any portion of any request that refers to documents that Google, Inc.

is aware of which were at one time within its possession, custody or control, but which

are not now within or subject to its possession, custody or control, Google, Inc. is

directed to identify such documents In a manner sufficient to describe such documents

for the purpose of preparing and serving a proper subpoena duces tecum and to give

the name, telephone number, and address of the person last known by Google, Inc. to

have been in possession, custody or control of such documents.

3. If any document requested by this subpoena has been destroyed, set forth



Case3:11-cv~00167-S! Document88-T Filed03/01/11 Page18of 31

DOCUiVlENT R E Q U E S T S

1. All information and documents related to the use of your servlce{s) to host

the content associated with and/or comprising the <www.geohotps3.blogspot.com>

website and any related subdomains,

2. Documents and electronic data reproducing all content, including but not

limited to text, images, comment text, and/orfiles, posted to or associated with the

<www.geohotps3.bloQspotcom> website and any related subdomains, from January 1,

2009 to the present.

3. Documents sufficient to identify all names; addresses, and telephone

numbers associated with the account associated with the

<wWw.geohotp33.bloQspot.com>.

4. - Documents reproducing ai! server logs, IP address logs, account


account identified in Request No. 3 above.

5. All documents related to any service that you have provided fo the

owner(s) or user(s) of the account identified in Request No. 3 above at any time,

whether physically or electronically stored.

, 6. Documents reproducing ali e-mails, correspondence, or other material

between you and any person related to the <www.geohotps3.bIogspot.com> website

and any related subdomains at any time.

63137261 v2

Case3:11~cV"00157-S! Document88-1 F!led03/01/11 Page20 of 31

AO 88B (Jlev. Ot/09) SubpoGoa to Produce DDcumenls, Infurmation, or Objects or to Permit Inspeclion of Premises

UNITED STATES DISTRICT COURT far the

Norihern District of California

Sony Computsr Entertainment America LLC )

Plaintiff ) V. ) Civil Action No. C-11-00167 SI

George Hotz; Hector Martin Cantero; Sven Peter; ) and Does 1 through 100 ) (if the action is pending in another district, state where:

Defendant )

S U B P O E N A T O P R O D U C E D O C U M E N T S , I N F O R M A T I O N , O R OBJECTS O R T O P E R M I T INSPECTION OE PREMISES

To: YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066

^Production: Y O U A R E COIMMAWDED to produce at the tune, date, and place set forth below the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: See Attachment A

Place: Kllpatrick Townsend & Stockton LLP Two Embarcadero Center, 8th Floor San Francisco, CA 94111

Date and Time;

03/1G/20-11 10:00

• Inspection of Premises: Y O U A R E C O M M A N B E D to pemit entry onto the designated piemises, land, or other property possessed or cont-oUed by you at the thne, date, and location set forth below, so that the requesting party may inspect, measure, survey, photograph, test, or sample the properly or any designated object or operation on it.

Place: Date and Thne:

The provisions of Fed, R. Civ. P. 45(c), relatmg fo your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relatmg to your duly to respond to this subpoena and the potential consequences of not doing so, ai-e attached.

Date: _ _ _ _ _ _ _

CLERK OF COURT OR

Signature of Clerk or Deputy Clerk Attorney's signature

The name, address, e-mail, and telephone number of the attorney representing (name of parly)

Sony Computer Entertainment America LLC , who issues or requests tliis subpoena, are:

Holly Gaudreau, Esq., Kllpatrick Townsend & Stockton LLP, Two Embarcadero Center, 8th Floor, San Francisco, California 94111; E-mail; hgaudreau(@kllpatricktownsend.com; Telephone: 415-576-0200

Case3:11-cv-00167-Sl Documents8-1 Ftled03/01/11 Page21 of 31

A O E8B CRev. 01/D9) Subpoena to Produce Dociimenls, InfoimatiDti, or Objects or to Permit Inspection of Premises (Page 2)

Civi l ActionNo. 0-11-00167 31

P R O O F OF S E R V I C E

(This section should not be filed with the court unless required by Fed. R. Civ. P, 45.)

TiliS subpoena for (name of individual and iiile. if any) ^

was received by me on ((/afej .

P I personally served the subpoena on the individual at (placs)

on (date) ; or

• I left the subpoena at the individual's residence or usual place of abode with (name)


on (dale) , and mailed a copy to the individual's last imown address; or

• I served the subpoena to (name of individual) - ' ^'"^^

designated by law to accept service of process on behalf of (name of organ izaiion)

an (dale) ; or

• I returned the subpoena unexecuted because '

• other (specify):

Unless the subpoena was issued on belialf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, ia the amount of

My fees are J for travel and $ for semces, for a total of $ 0.00

I declare under penalty of perjury that this information is true.

Date: Server's signature

Printed imne and title

Sen'ei-'s address

Additional information regarding attempted service, etc:

Case3:11-cv~00167-SI Document88-1 Filed03/01/11 Page22of 31

AO EBB (Rev. Ql/Pg) Subpoena ia Praducg Dacumenia, Infornialipii, or Objects or to Permit Inspeclion of Premises (Page 3)

Federal Rule of Civil Procedure 45 (c), (d), and (e) (Elfective 12/1/07)

(c) Protecting a Person Subject to a Subpoena. " {\)"Avoidmg Undue Burd&n or Expense; Sanctions. Aparty or attorney responsible for issuing Eind serving a subpoena must toice reasonable steps to avoid imposing undue burden or expense on a person subject to tl:e subpoena. The issuing coiut must enforce this duty and IrapoBe an appropriate sancdon — which may include lost earninga and reasonable attorney's fees — on a paity or attorney who fails to comply.

(2) Coin mand to Produce Materials or Perm it Inspection. (A) Appearance Not Required. A person commanded to produce

documents, electronicaliy stored information, or tangible things, or to permit the inspi:M;tion of promises, need not appear in person at the place of production or hspection unless also commanded to appear for a deposition, hearings or trial.

(B) Objections. A person commanded to produce doDuraents or tangible things or to permit inspection may serve on ttie party or alterney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of die materials or to inspecting the preniises — or to producing electronically stored information in the fo]-m or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after tlie subpoena is served. If an objection is made, the following rules apply:

(i) At any time, on notice to the commanded person, the serving paity may move the issuing court for an order compeUiag production or inspection.

(ii) TJiese acts may be required only as directed in the order, and die order must protect a person who is neither a party nor a party's officer fi-om significant expense resnlthig ftom compliance. (3) Quashing or Modifying a Subpoena. (A) Wlien Required. On timely motion, the issuing court must

qua.'ih or modily a subpoena that: (i) fails to allow a reasonable time to comply; (fi) requires a person who is neither apai- nor apaity's officer

to travel more than 100 miles iiom where tliat person resides, is employed, or regularly iTansactg business in person—except that, subject to Rule 45Cc)(3)CB)(iii), the person may be commanded to attend atrial by traveling fi'om any such place •within tlie state where the trial is held;


(iv) subjects a person to undue burden. (B) When Permitted. To protect a person subject to or affected by

a subpoena, the issumg court may, on motion, quash or modify the subpoena if it requires;

(i) disclosing atrade secret or other confidential research, development, or commercial information;

(ii) disclosing an unretained expert's opinion or information that does not descrilje specific occurrences in dispute and resuhs from the expert's study that was not requested by aparty; or

(iii) a person who is neitber apariy nor aparty's officer to incur substantial expense to travel more than 100 miles to attend trial.

(C) Specifying Conditions as an Alternative. In tlie circumstancBS described in Rule 43(c)(3)CB), the court may, instead of quasliing or modifying a subpoena, order appearance or production under specified conditions if the serving party:

(i) shows asubatantia! need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensui'es that the subpoenaed person will be reasonably compensated.

(d) Duties in Responding to a Subpoena. (1) Producing I>ocumenis or Electronically Stored Information.

These procedures apply to producing documents or electronically stored infonnafion:

(A) Docwnents. A person responding to a snbpoena to produce documents must produce them as tlisy are kept in the ordinary course of business or must organize and label them to cortespond to the categories in the demand.

(B) Form for Producing Electronically Stored Information Not Specified. If a subpoena does not specify a form for producing electronically stored information, tha person responding must produce it in a form or forms in wliicli it is ordinarily maintained or in a reasonably usable form or forms.

(C) Electronically Stored Information Produced in Only One Form. The person responding need not produce the same eleotronically stored information in more than one form.

(D) Inaccessible Electronically Stored Information. The person responding need not provide discovery of elecii-omcally stored information &om sources that tlie person identifies as not reasonably accessible because of undue burden or cost On modonto compe! discovery or for a protective order, the person responding must show that tlie informadon is not reasonably accessible because of undue burden or cost. If tiiai showing is made, the court may nonetheless order discovery firom such sources if the requesting party shows good cause, considermg the lunitations of Rule 26(b)(2)(C). The court may specily condifions for the discovery. (2) Claiming Privilege or Protection. (A) Information Witiiheld. A person withholding subpoenaed

information under a claim diat it is privileged or subject to protection as trial-prepaj'ation material must:

(i) expressly iiiake the claim; and (ii) describe die nature of the withheld documents,

communications, or tangible diings in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim. (B) Ii formation Produced. If information produced in response to a

subpoenais subject to a claim ofprivilege or of protection as trial-preparation material, the person malcing the claim may notify any party that received the information of tlie claim and the basis for it. After being notified, a party must promptly return, sequester, or desti'oy the specified information and any copies it has; must not use or disclose tlie information until the claim is resolved; must talce reasonable steps to relieve the information if the party disclosed it before being notified; and may promptly present the information to the court under seal for a determination of the claim. The person who produced the information must preserve the infoi-malion until the claim is resolved,

(e) Contempt. The issuing court may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena. A nonp.arly's failure to obey must be excused if the subpoena purports to require the nonparty to attend or produce at a place outside the Ihnits of Rule 45(c)(3) (A)(ii).

Case3:11 -cv~00167-Si Document88-1 Fi!ecl03/01/11 Page23 of 31

A T T A C H M E N T A

INSTRUCTIONS

1. YouTube, LLC is directed to furnish all documents, including electronically

stored information, in its possession, custody or control.

2. As to any portion of any request that refers to documents that YouTube,

L L C is aware of which were at one time within its possession, custody or control, but

which are not now within or subject to its possession, custody or control, YouTube, L L C

is directed to identify such documents in a manner sufficient to describe such

documents for the purpose of preparing and serving a proper subpoena duces tecum

and to give the name, telephone number, and address of the person last known by

YouTube, L L C to have been in possession, custody or control of such documents.

3. if any document requested by this subpoena has been destroyed, set forth



Case3:11-cv-00167-Si Document88-1 Filed03/01/11 Page24 of 31

DQCUiVlENT R E Q U E S T S

1: All information and documents related to the use of your service(s) to host

the content associated with and/or comprising the video titled "Jailbroken PS3 3.55 with

Homebrew", posted by user "geohot" and located at

<http://www.youtube.Gom/watch7v=UI<LSXsCKDkg>.

2. Documents sufficient to identify all names, addresses, and telephone

numbers associated with the "geohot" account(s).

3. Information and documents sufficient to identify how many users currently

have access to the "private" video identified in Request No. 1 above, or have had

access to the "private" video identified in Request No. 1 above from January 27. 2011

until tiie present.

4. Information and documents sufficient to identify the usernames and/or

accounts that currently have access to the "private" video identified in Request No. 1

above, or have had access to the "private" video identified in Request No. 1 above from

January 27, 2011 untii the present.

5. Documents reproducing all records of usernames and IP addresses that

have posted or published "comments" in response to the video identified in Request No.

1 above from January 27, 2011 until the present.

6. Documents reproducing the text of ali "comments" posted or published in

response to the video identified in Request No. 1 above from January 27, 2011 untii the

present,

7. Documents reproducing all server logs, IP address logs, account


"geohot" account identified in Request No. 1 above. 8. Documents reproducing all e-mails, correspondence, or other material

between you and the user "geohot".

Case3:11-cv~00167-S! Document88-1 Filed03/01/11 Page25of31

9. All documents related to any sen/ice that you have provided to the owner

of the "geohot" account identified in Request No. 1 above at anyt ime.

631372S9 v2

IN T H E SUPERIOR C O U R T O F F U L T O N C O U N T Y STATE OF G E O R G I A

B E R T H A SMILEY,

Plaintiff,

V .

W I L L I A M SMILEY,

Defendant.

CIVIL ACTION

FILE NO.

P L A I N T I F F ' S F I R S T R E Q U E S T F O R A D M I S S I O N S T O W I L L I A M S M I L E Y

T O : "WILLIAM SMILEY, Defendant and liis Attorney of Record, Family Lawyer, Esquire 101 Concordia Lane Atlanta, Georgia 30303

Plaintiff, pursuant to O.C.G.A. §§ 9-11-26 and 9-11-36 of tlie Georgia Civil Practice Act,

requests that Defendant respond in the time and mainaer required by law to the following

requests to admit factual matters set forth below.

Defendant is hereby requested to admit or deny, for puiposes of flie pending action, flie

tmth of each of the following statements of fact and of the application of law to fact. This

request for admissions is made pursuant to Rule 36 of the Georgia Civil Practice Act, O.C.G.A. §

9-11-36 et seq., and other applicable law. Admissions or denials shall he answered folly in

writing and mider oath within thirty (30) days from the date of service thereof

Each Request to Admit is addressed to the personal loiowledge of Defendant, as well as

to the loiowledge and information of Defendant, his attorneys, agents, and other representatives.

When a question is dii-ected to Defendant, the question is also directed to each of tlie

aforementioned persons. Any reference hereinbelow to Defendant, William Smiley, "you", or

"your" refers to the Defendant.

Plamtiff requests that Defendant admit the following:

1.

Admit you .maintain, and/or have maintained in the last twelve months, an account with

tlie website Facebook.com.

2.

Admit you have, tlnough your Facebook account, joined a Facebook group called "I Hate

My Wife."

3.

Admit that on or about January 15, 2011, you posted a "status update" on your Facebook

page stating: "I don't care how much it costs me, I don't care what I have to do, my wife is

gomia get wliat's coming to her!"

4.

Admit you are aware your daughter, Natalee Smiley, has a Facebook account.

5.

Admit that you ai'e "friends" with Natalee Smiley on Facebook.

6.

Admit that an album entitled "Mai'di Gras!! NO L A March 4-6, 2011!!!" contains

photographs of you talcen on or about the dates of Mai'ch4, 5, and/or 6, 2011.

7.

Admit that the photograplis referenced in Request No. 9 above are accurate depictions of

you in New Orleans, Louisiana on or about March 4, 5, and/or 6, 2011.

8.

Admit that you are Facebook "fiiends" or have been Facebook "friends" at any point in

the past twelve months with an individual Icnown as Heather Birdley.

9.

Admit that, on or about Mafch 7, 2011, you received the following message on yom-

Facebook wall from Heather Bkdley; "NOLA was so much fim!! ;) I can't wait to see you agam

this weekendl X O X O X O . "

10.

Admit you gave Heather Bhdley a "lovebhd gift" on Facebook on or about March 15,

2011.

I L

Admit that, as of fbe date of tlie witlnii Requests, Heaflier Birdley's Facebook profile

indicates she has not yet reached eighteen (18) years of age.

12.

Admit that you mamtam, and/or have maintamed in the last twelve months, an account

with the website Match.com.

13.

Admit that, as of the date of the witliin Requests, your Match.com profile states your

relationship status is "Single."

14.

Admit tliat, as of the date of the witliin Requests, your Match.coni profile states you have

no cliildren.

15.

Admit that, as of the date of flie withhi Requests, your Match.com profile states you earn

"$150,000+" per yeai*.

16.

' Admit that, as of the date of the within Requests, your Match.com profile states: "I enjoy

yachting, fine dining, international travel, and Gucci shoes."

Respectfully submitted,

F A M I L Y L A W Y E R & ASSOCIATES, P.C.

Bv: , Family Lawyer, Esq. Georgia Bar No. 123456 Attorney for Plaintiff

Suite 480 6100 Lake Foijest Drive Atlanta, Georgia 30328 (404) 806-7330

Prepared for Inns of Court By Oni Seliski & Sandy Bair

H o w do I take a s c r e e n s h o t ?

press = Windows captures the.entire screen and copies it to the cHphoard,

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o f 9

From: Simon

Subject: M Discussions about school - IMPORTANT INFORMATION IN H E R E

Session Start (i

[13:00] Jamey

[13:00] Jamey

[13:01] Jamey

[13:01] Simon

[13:01] Simon

[13:01] Jamey

[13:01] Jamey: no they're not but why

[13:01] Jamey: he is all grown up

[13:01] Jamey; you Icnow we have to start researching private schools this year

[13:01] Jamey: some apps are due by next jan

[13:02] Jamey: then testing and interviews

[13:02] 5 i m o n l i ^ i ^ W i a ^ i ^ g i ^ a M < ^ I think the car seat belt provides the best imapct protection so once they

are big enough they use that

[13:02] Jamey: i guess, i stil! would like sometliing that attaches the seat to the car

[13:03] Simon ^^^ms^x^^^^g^m Send me the ones you think are good choices and I'll start some research

[13:03] Jamey: I've got it down to 4

[13:03] Jamey: wesleyan school (Link: www.wesleysnschool.orgjwww.westeyanschool.org

[13:03] Jamey: woodward academy (Link: www.woodward.edu)www.woodward.edu

[13:03] Jamey: Westminster schools (Link: www.westminster.net)www.Westminster.net

[13:04] Jamey: greater atanta christian (Link: www.greateratlantachristian.org)www.greateratlantachri5tian.org

[13:04] Jamey: the first 3 are very prestigious

[13:05] Jamey; the last one is not so much

[13:05] Jamey: but I'm concerned about the education, not prestige

[13:05] Jamey: ok, maybe a little concerned about prestige

[13:05] Jamey::)

[13:06] Jamey: i want a school that has a great academic program but all a good sports program

[13:07] S i m o n ^ ^ ^ g ^ ^ ^ ^ ^ ^ g And we can afford and is located a resonable distance

[13:07] Jamey: forgeign language and computers are just as important to me as the other things that are

required

[13:08] Jamey: Westminster is the only one that isn't in close proximity to us

[13:08] Jamey: they are all about the same cost per yesr

[13:08] Jamey: year

[13:09] Jamey: $10^14K

[13:10] Jamey: they have a campus in duluth

[13:10] Jamey: spencer would only have to go to college park for high school

[13:10] Jamey: and by that point who knows

[13:10] Jamey: maybe they will build a new facility closer

[13:11] Simon ^ ^ ^ ^ ^ ^ ^ M ^ ^ looks like tuition is due in full before they start the year

[13:13] Jamey: iVe done quite a bit of research and i really believe these are the best for him ^fmmmmmm

8/12/2008

of 9

[13:16] Jamey: i even inspected the menus at these schools :)

[13:19] Jamey: and I don't want the graduating class to be to small

[13:19] Jamey: i would like to him to have some interaction with kids

[13:19] Jamey: but of course not to big either

[13:19] Jamey: 500 kids is ilMSANE

[13:20] Jamey: i'm thinking at least 100

[13:20] Simon ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ I ' m having a hard time finding the hours he would go to school for each

one.

[13:20] Jamey: i haven't looked at that

Session Close (Jamey): Tue Jan 16 13:30:53 2007

Session Start ^ ^ ^ ^ I ^ ^ B ^ ^ ^ J a m e y Michelle): Sun Mar 09 17:21:37 200S

[17:21] Jamey Michelle: hey

[17:21] Jamey Michelle: he's exhausted

[17:22] Jamey Michelle: two neighbors came over and wore him out

[17:22] Jamey Michelle: I'll be lucky to get him in the bath befor he crashes

[17:22] Jamey Michelle; have you found out which school serves your neighborhood?

[17:23] Simon W ^ ^ ^ ^ ^ ^ S S ^ ^ ^ Morr is Brandon. Banks' Father who I talked to at the field trip, said that

would be the only public school he would send his kids to, he says it's incredible and the IB program is equialiy as

Incredible.

[17:23] Simon W ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ I was going to stop by and pickup the papers and literature for it on

Thursday or Friday, to show to you.

[17:24] Simon i ^ ^ ^ H ^ ^ ^ ^ ^ ^ But I'm convinced we be crazy to pay for private school with that

available to us,

[17:24] Jamey Michelle: we need to compare it to riverside

[17:24] Simon ^ l ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ a s o you aren't moving to another discrict?

[17:24] Jamey Michelle: i would like to compare the school where you are to the school where 1 am

[17:24] Jamey Michelle: I'm not sure if I'm moving or not

[17:24] Jamey Michelle: 1 have alot of decisions to mai<e

[17:25] Jamey Michelle: i want to do whatever is best for spencer

[17:25] Jamey Michelle: if the school by_you is the best then h e X K S j h e r e

[17:25] Simon ^ ^ ^ i i ^ ^ i i ^ ^ ^ ^ g p l ' f e i i ^ i r i ^ r n n v i n r p H Morris Brandon is incredible based on my research

and people I've talked to.

[17:25] Jamey Michelle: have you looked at riveslde?

[17:26] Jamey Michelle: I'm not trying to put up roadblocks or anything, i'm just asking

[17:26] Jamey Michelle: like i said, i will do whatever is the best for him

[17:26] Jamey Michelle: if i stay in this house then I'll just have to drive alot

[17:27] Jamey Michelle: or have him thurs-sun

[17:27] Simon t ^ ^ ^ B ^ ^ p i ^ i S E a e M R i v e r s i d e isn't a member of the IB program, and has a higer student to

teacher ratio.

[17:27] Jamey Michelle: i'm open to whatever

[17:27] Jamey Michelle: what's the ib prograrii?

[17:28] S i m o n " i H M l j ^ ^ ^ i ^ ^ ^ ^ (Link: http;//www.ibo.org/school/002422/)

http:/ /www.ibo.org/school/002422/

[17:28] Simon S M ^ S S ^ ^ ^ B ^ S i l Banks' Father said It's incredible

[17:30] S i m o n i ^ M ^ M I f f i l ^ ^ B B ^ m l do need to get his registration In before 4/1 to get our choice of

Kindergarden teacher. So when you get a chance do your research and let me know where you stand.

[17:31] Simon ^ ^ ^ a m m : ^ ^ ^ ^ ^ ^ Also ! need to get his summer camp registaion in before 3/15 to receive

8/12/2008

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Lei our siafl of trained prolessiorals enamine your evidence and provide a comprehensive report of all the information on \t\s phone. Aduanced analycis inckidinfl dala carving, deleted data rGCOvery, a ceil phone lower location analysis, as well as eiiperi witness leslimony is also eveilable

Every mobile device Is difierEni and different results will occur based on lhal device. We do our best wiih each unit we recisivB lo relneue Ihe maximum amount ol iiilormation. No mailer what dala is retrieved Irom the device you viiill be cnarged a minimum .?100 DO lee.

Advancfid Hsndheld Forensic Analysts

Paraben's e>pen team ol forensic ejiainlnars can perform a complete forensic examinalion ol call phones and PDAs. The dais available on e liandhelcl device can be crucial. Searching and Ihoroughiy analysing lhal dala far inlnrmalton p&dineni lo your case Is only Ihc- beginning. Timelines, link analysis, cell lavmt analysis, billing anelysis, and more can help give you mere than you Ihoiighl possible

Besides s Kperl analyniti o! dala Irom actual devices, ULir consultanis can help you obtain scttral call records, account inlormsition. and other dala Irom the provMers Ihrough court-orders, subpoenas, eln

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vWlh our basic forensic analysis, we will create e forensic Image ol the phone and crsate a detailed HTIWL report otall Ihe dais available on ihe phene. You can then perloim your own analysis ol this data. OiricU, simplH, forenslcally sound.

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.Scmeiime all you need is iniormaiion and you need it now. TOili our noti-foransic service, you can skip ilia ilme corisuming lorensic procadures anti sliip us your device loday. We'll take a complete image ol alt llie data on Ihe pnone. including any deleted lexl messagEs or photos (If possible), and we'll ship back Ihe phone with a ccimprefiensivB HTML report ol avorvthing on llie device.

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hl1p://www.parabeii--consultmg.coiiiyservices.html 5/10/201

Apr i l 17, 2011

VIA CERTIFIED MAIL RETURN RECIPT REQUESTED

F i d e l i t y Brokerage Se rv ices LLC c/o i t s r e g i s t e r e d agent C T Corpora t ion System 1202 Peachtree S t r e e t , NE A t l a n t a , Georgia 30361

Re:

DEMAND FOR PRESERVATION

Dear Madam:

nnr- f i r m reoresents wi th regard to the above-s t y l e d matteT. l e t t e \ T T t ^ T i l ^ o t i c e to F i d e l i t y Brokexage services, LLC and i t . e n t i t y hrsource that i t i s to d e s t r o y , conceal or a l t e r i n any manner whatsoever any or f j ^ ^ ^ " ^ ^ ^ ; documents, i n f o r m a t i o n , paper or e l e c t r o n i c data and/or o the r t a n g i b l e Items ' p e r t a i n i n g or r e l evan t to or P " P f Y i m i t e ' d " to in the above-referenced matter i n c l u d i n g but not l i m i t e d t o a l l recordings f rom September 1, 2009 forward r e l a t i n g to

This n o t i c e i n c l u d e s , but i s not l i m i t e d t o , a l l data

generated and/or s t o r e d on any and a l l - - P ^ ^ - - " ^ t ' t v p e ' s u c r : ' on any and a l l o ther e l e c t r o n i c storage media of any type ^ " ^ h as hard d i s k s , f l o p p y d i s k s , CD-ROMs, DVDs, f l a s h d r i v e s , backup S e s , on l ine b a c L p s e r v i c e s or any ° t h e r s torage me ^ ^ ^ ^ s e r v i c e ; a l l e m a i l s ; a l l i n s t a n t messages; a l l SMS t e x t messages a l l audio data such as vo i ce m a i l , tape r eco rd ings d i g i t a l r eco rd ings ; and- a l l photographs, v ideos , w r i t i n g or o the r documentary m a t e r i a l of any na tu re .

F i d e l i t y Brokerage S e r v i c e s , LLC and hrsource are t o talce whatever s teps are necessary to avo id d e s t r u c t i o n of ev idence I t i s a n t i c i p a t e d tha t these i tems w i l l be used m evidence m for thcoming l i t i g a t i o n .

In order to assure that your o b l i g a t i o n to preserve documents

and t h i n g s w i l l be met, please forward a copy of t h i s l e t t e r t o any and a l l persons and e n t i t i e s w i t h c u s t o d i a l r e s p o n s i b i l i t i e s f o r the items r e f e r r e d h e r e i n .

Very t r u l y yours,

Gwenn Dorb H o l l a n d