SUBP-010
ERT ES a mines rare
|George sh
eal Nar Heit Road, #620
m Diego,
27 Dieenincho- 310-498-4455 ‘nun
ronaltt 208885. george@clippercp.com
ATTORNEY FOR ewe Ty Propria Persona
‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Diego
smmecrooness 330 W. Broadway
agai none
envwwzcoe San Diego, CA 92101
wuscanme Central Division
puanmFrieermoner: George Sharp
DEFENDANTRESPONDENT: StockTips.com
DEPOSITION SUBPOENA ee
FOR PRODUCTION OF BUSINESS RECORDS 37-2015-0008210-CU-NP
‘THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, it known):
Custodian of Records for AWeber Communications , 1100 Manor Drive, Chalfont, PA 18914
4. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in Item 3, as follows:
To (name of deposition officer): Victoria Loera
‘On (date) : October 9, 2015 ‘At (time): 10:00am
Location (adores): 13681 Newport Avenue, Suite 8-608, Tustin, California 92780
Do not release the requested records to the deposition officer prior to the date and time stated above
‘a. L by delivering a true, legible, and durable copy of the business records described in item 3, enclosed in a sealed inner
‘wrapper wth the tile and number of the action, name of witness, and date of subpoena clearly written on it, The inner
wrapper shall then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposition officer at the
address in item 1.
b, (1 by delivering a true, legible, and durable copy of the business records described in item 3 to the deposition officer at the
wilness's address, on receipt of payment in cash or by check ofthe reasonable costs of preparing the copy. as determined
under Evidence Code section 1563(b).
c. [1 by making the original business records described in item 3 available for inspection at your business address by the
altomey/s representative and permitting copying al your business address under reasonable conditions during normal
business hours
2. The records are to be produced by the date and time shown in item 1 (but not sooner than 20 days after the issuance of the
deposition subpoena, or 15 days ater service, whichever dete is later). Reasonable costs of locating records. making them
‘available or copying them, and postage, f any, are recoverable as set forth in Evidence Code section 1563(t). The records shall be
‘accompanied by an affidavit of the custodian or other qualified witness pursuant to Evidence Code section 1561
13, The records to be produced ate described as follows (i electronically stored information is demanded, the form or
forms in which each type of information is to be produced may be specified):
(71 Continued on Attachment 3.
4.IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS UNDER
‘CODE OF CIVIL PROCEDURE SECTION 1985.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION HAS BEEN
SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WITNESSES, AND CONSUMER OR EMPLOYEE
AFFECTED MUST BE OBTAINED BEFORE YOU ARE REQUIRED TO PRODUCE CONSUMER OR EMPLOYEE RECORDS.
DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE
iE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
Date issued: .
Michael Roddy yp Made
Tec ORPRNT WN {NATURE OF PERSON SSUING IGEN
_—________GLERK OF THE COURT —_
(Proof of service on reverse) sae Paget ct
: DEPOSITION SUBPOENA FOR PRODUCTION Coat Gt rcs 202041020704
wire wey 302) OF BUSINESS RECORDS teSharp v. StockTips,com
CASE NO. 37-2015-0008210-CU-NP
ATTACHMENT 3
Deposition Subpoena for Production of Business Records to
Custodian of Records of AWeber Communications
1100 Manor Drive, Chalfont, PA 18914
. All documents, including but not limited to electronic Documents, showing
the names, addresses. phone numbers and other contact information of
the entities and/or persons for whom you disseminate emails on behalf of
the return email address “Paul@StockTips.com”.
|. All documents which show any predecessor return email addresses for the
account currently operated under the return email address
“Paul@StockTips.com”.
. All account opening documents for your client that operates under the
return email address “Paul@StockTips.com” or predecessor email
addresses.
. All communications, including but not limited to emails, letters, invoices,
voice mails and contracts, between you and the account operated with the
return email address “Paul@StockTips.com” or predecessor email
addresses.
. All documents which show payments received by you for the account
operated with the return email address “Paul@StockTips.com” or
predecessor email addresses.
. All documents which show any verification or research conducted by you of
the identities of those who operate the account under the return email
address “Paul@StockTips.com’” or predecessor email addresses.
|. All documents which show any verification or research conducted by you of
the legitimacy of any corporation or other business entity associated with
the account operated under the return email address
“Paul@StockTips.com” or predecessor email addresses.
. All documents, including but not limited to electronic files, which detail the
creation or uploading of the initial database of recipients of emails
disseminated from the account operated under the return email address
“paul@StockTips.com” or predecessor email addresses.
. All communications , including but not limited to emails, letters, invoices,
voice mails and contracts, between you and Amerada Corp.POS.030
[TORREY GR FT WATNGUT ATTORNEY Si ow For counT stony
George Sharp
13525 Del Mar Heights Road, #620
San Diego, CA 92130
reeroneno.310-498-4455 meno. on
eure rooeessonomgeorge(@clippercp.com
nowerson pmesin Propria Persona
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Diego
street aporess 330 W Broadway
vee
A Diego, CA 92101
mncrveeContral Divi
Saronic ane O&OTEE STP
RESPONDENTIDEFENDANTStOCkTips.com
PROOF OF SERVICE BY FIRST-CLASS MAIL—CIVIL 37-2015-00008210-CU-NP-CTL
(Do not use this Proof of Service to show service of a Summons and Complaint)
4, 1am over 18 years of age and not a party to this action. | am a resident of or employed in the county where the mailing
took place.
2. Myresidence or business address is:
3525 Del Mar Heights Road, #620, San Diego, CA 92130
3. On (date):August 31,2015 mailed trom (city and stae)-San Diego, California
the folowing documents (speci
Deposition Subpoena for Production of Business Records
Attachment 3
[1 The documents are listed in the Attachment to Proof of Service by First-Class Mail—Civil (Documents Served)
(form POS-030(0)).
4. served the documents by enclosing them in an envelope and (check one).
a. G21 depositing the sealed envelope with the United States Postal Service with the postage fully prepaid.
tb. [1] placing the envelope for collection and mailing following our ordinary business practices. | am readily familiar with this
business's practice for collecting and processing correspondence for mailing. On the same day that correspondence is
placed for collection and mailing, itis deposited in the ordinary course of business withthe United States Postal Service in
‘a sealed envelope with postage fully prepaid.
5, The envelope was addressed and mailed as follows:
a. Name of person served:Custodian of Records, AWeber Communications
b, Address of person served:
1100 Manor Drive, Chalfont, PA 18914
[1 The name and address of each person to whom | mailed the documents Is listed in the Attachment to Proof of Service
by First-Class Mail—Chvl (Persons Served) (POS-030(P))
| declare under penalty of perjury under the laws ofthe State of CaBfomia th
Date: August 31, 2015
Is tue and correct.
CTYPE OF PRINT WE O PERSON COMPLETING TS FORW [BNR 0 PERN COMPLET SOR
Boater a can PROOF OF SERVICE BY FIRST-CLASS MAIL—CIVIL Gade ol Prcnn 0T e
‘Sst New ny 00) (Proof of Service) ens
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