SUBP-045

us om~

ATrORNEY ORPARTY WTI4OUT ATTORNEYINan,. StateB.r number, anda62'22)

-ackie Rose Kruqjer, Esq. (# 231085)

485 South Robertson Blvd.. Suite 4
90211
Beverly Hills. California 550-1234
NO.: (310)
TELEPHONE
E4AWLADDRESS: irkruqedawaUamaii.comn
ATTORNEYFORlNSM~).

FAXNO-:

ErkRkr

Court for county in which discovery Isto be conducted.

SUPERIOR COURT OF CALIFOR~NIA, COUNTY OF Sacramento

720 9th Street

$TREETAOORESS:

ADDRESS:
MAJUNG
CITY AMOZIP CODE:

Sacramento, CA 95814

NAME-'
BRANCHI

Court in which action i3pending: Superior Court of New Jersey

Name of Court: County of Hudson, Civil Division #4

583 Newark Avenue

STREETADDRESS:

ADDRSS:~
MAILING

Jersey City, New Jersey 07306

rITY. STATE.ANDOZIPCODE:
COUNTRY:

PLAINTIFFIPETITIONER:
DEFENDANTIRESPONDENT:

Lane Bajardi, et at.

CLFRI

AENME I ywindb

.)

Nancy Pincus, et at.

DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND

PRODUCTION OF DOCUMENTS, ELECTRONICALLY STOREDL-731

INFORMqATION, AND THINGS INACTION PENDING OUTSIDE CALIFORNIA I

CAENME

o co prn

jd

afna

-73-

THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponen4 if known).
CA 95833
Google, Inc. c/o CSC - Lawyer Ilncorp Ser, 2710 Gateway Oaks Dr Ste 150, Sacramento,
date, time,
1. YOU ARE ORDERED TO APPEAR INPERSON TO

TESTIFY AS A WITNESS in this action at the following

and place:_

Time: 5:00 pmn

FDate: Sept. 7, 2012

Address: Ms. Jackie Rose Kruger Listed Above

on your behalf as
a deponent who is not a natural Derson, you are ordered to designate one or more persons to testify
iziAs
to the matters described initenm 4. (Code Civ. Proc., 2025.230.)
in item 3.
b. tJYou are ordered to produce the documents, electronically stored information, and things described

a.

through the instant visual display of testimony

c. This deposition will be recorded stenographically =
= videotape.
audiotape
and by =
records are required by this
2- The personal attendance of the custodian or other qualified witness and the production of the original
deemed sufficient compliance
be
not
will
1562
and
1561,
1560(b),
sections
Code
Evidence
by
subpoena. The procedure authorized
with this subpoena.
being sought are described
3. The documents, electronically stored information, and things to be produced and any testing or sampling
is to be produced
as follows ((if electronically stored information is required, the form or forms in which each type of information
may be specffleO : Please see Attachment 3

mContinued

on Attachment 3 (use form MC-025).

is to be examined are described
4. If the witness is a representative of a business or other entity, the matters upon which the witness
as follows:
Continued on Attachment 4 (use form MC-02 5).
and name of party
5. Attorneys for the parties to this action or parties without attorneys are (name, address, telephone numbher,
represented):
F-

Please see Attachment 5

Pa" I of2

SContinued on Attachment 5 (use fiorm MC-025).

AdoowfoMenaUo
Fmm
SUB45le J

Lee

DEPOSMON SUBPOENA FOR PERSONAL APPEARANCE AND c=GCP

2RO2S:
PRODUCTION OF DOCUMENTS, ELECTRONICALLY STORED
INFORMATION, AND THINGS IN ACTION PENDING OUTSIDE CALIFORNIA

1. 20121l

,!22.0-W
arWn4

SUBP-045
PLAINTIFF/PETITIONER: Lane BaJardi, et al.
DEFENDANTIRESPONDENT: Nancy Pincus, et al.
6-

CASNUMBER:

Other terms or provisions from out-of-state subpoena, if any (specify):

mContinued

on Attachment 6 (use form MC-025J.

7. If you have been served with, this subpoena as a custodian of consumer or employee records under Code of Civil
Procedures 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, witneuses, and consumer or employee affected must be obtained before you are required to
produce consumer or employee records.
8. At the deposition, you will be asked questions under oath, Questions and answers are recorded stenographically at the deposition;
later they are transcribed for possible use at trial. You may read the written record and change any incorrect answers before you
sign the deposition. You are entitled to receive witness Wes and mileage actually traveled both ways. The money must be paid, at
the option of the party giving notice of the deposition, either with service of this subpoena or at tihe time of fth deposition. Unless tihe,
court orders or you agree otherwise, if you are being deposed as an individual, the deposition must take place within 75 miles of
your residence. The location of the deposition for all deponents is governed by Code of Civil Procedure section 2025.250.
DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE
FOR THE SUM OF $600 AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
Date issued.
I

Jackie Rose Kruger, Esq.

SUBPOENA)
ATRE OFPERSON ISSUING

Attorney Fd Plaintiff
crn1.E

NAME)
(TYPE
ORPRANT

PROOF OF SERVICE OF DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND PRODUCTION OF DOCUMENTS,
ELECTRONICALLY STORED INFORMATION, AND THINGS
I1.I served this Deposition Subpoena for Personal Appearance and Production of Documents, Electronically Stored Information, and
Things inAction Pending Outside California by personally delivering a copy to the person served as follows:
a. Person served (name):
b. Address where served:
d. Time of delivery:

c. Date of delivery:
a. Wtness fees and mileage both ways (check one):
(1)

were paid. Amount ...........

_______

(2)
(3)

were not paid.

were tendered to the witness's public entity employer as required by Government Code section 68097.2. The
amount tendered was (specify):
$ ________
$ _______
........
I. Fee for service: ...........

2. 1received this subpoena for service on (date):

3. =n I also served a completed Proof of Service of Notice to Consumer or Employee and Objection, (form SUBP-025)
by personally delivering a copy to the person served as described in 1 above.
.4 Person serving:
a. E]Not a registered California process server
California sheriff or marshal
b.
Registered California process server
c.
d.
Employee or independent contractor of a registered California process server
Exempt from registration under Business and Professions Cede section 22350(b)
e.
I. Name, address, telephone number, and, if applicable, county of registration and number

I declare under penalty of perjury under the laws of the State of

California that the foregoing is true and correct
Date:
ISIGNATURE)

SUEF05[5J..ny

1.20121

(For California sheriff or marshal use only)

I certify that the foregoing is true and correct.
Date:
(SIGNATURE)

DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND

PRODUCTION OF DOCUMENTS, ELECTRONICALLY STORED

INFORMATION, AND THINGS IN ACTION PENDING OUTSIDE CALIFORNIA

Pag2 f

MC -025
SORT TITLE:

CASE NUMBER

L-3723-12

Lane Baljardi. ct al. v. Nancy Pincus, et al.

ATTACHMENT (Number.

(This Attachment may be used with any Judicial Council form)

DOCUMENTS SUBPOENAED
EMAIL ACCOUNT INFORMATION REQUESTS
I.) Please produce the Internet Protocol ("IP") address log4 records for all Screen Namnes. IP Addresses. Log
Records, Telephone Numbers. Addlresses, Names Of Registrants, Addresses , email addresses as sociated with
the following Uniflormn Resource Locators ("URL"):
a. lhttp:H/grafixaveilgcr.blogspot.com/2011 /06/ba jardi-awvol.htmnl
Sunday. June 5. 2011 Posted by bludiamonds at 9:23 PM
b. littp://Igrafitxa\'cniger.blogspot.com/2011II/06/sii2gi-like-bird.hti-nl
Wednesday, JuLne 8. 2011 Posted by plIywood at 6:28 PM
c. lhttp://grafixavcenoer.blopspot.com-/20l11/06/singaing-Iike-bird.litinI
Wednesday. June 9. 2011l Posted by davidd at 7:05 AM
d. lhttp://oraltixavetiger.blogspot.coii/2011l/09/lenlzbiais,.m.lhtml
Tuesday, September 27. 2011 Posted by ss1959 at 11:3 1AM
c. hitp://grarixaveilger.bloospot-coiii/20 12/02/ga-exclusi,.e-petitioil-leaked.lhtml
Saturday, February I L 2012 Posted by Hobokenleaks at 11: 11 AM
I' littp://Qraf-ixavecngcr.blogspot.coin/201 2/03/citv-bud.,ets-b\,-eric-kuirta.htll
Thursday, March , 2012 Posted by Hoboken Answer at 11:20 AM
li ttp://grafixavcniger.blogspot.com/201 2/03/Joy,-olI-cookiing-boe-cinrollmenit-200-)-2008. html
Tuesday. March 6. 2012 Posted by Infotainmne at 5:24 AM
h. hittp://grafixavenger.bloaspot.comn/201I2/03)/silcnce-on-lecnz.lhtml
Monday. March 12, 2012 Posted by Rcdrider765 at 8:12 PM
i. lhttp://grafixavengtcr.blogspot.comn/201 2/03/silenicc-oii-lenz.htll
Mlondav, March 12, 2012 Posted by JAM at 9:46 PM
j. littp:f/grafixa\,engcr.blogspot.com/201 I2/04/als-reigil-or-terror.htiil
Sudy April 15, 2012 Posted by HobokenLleaks at 12:02 PM
2.) Please produce the following infoniination for each the above service(s) including but not limited to: type
of connection (e.g.. modemn. cable/DSL, T I/LAN): user name associated w,%ith thle connection: and telephone
caller identification records if connection was made by modern.
3.) 1fihle accouLn t hol der or user is a corporaltion or other non-person en tity please produce the enti ty's namei
and a contact person within entity.
4.) If your user is an individual please produce thle customer's name, User name, and screen namei(s).

(it the item that this Attachment concerns is made under penalty of perjury, all statements in this
Attachment are made under penalty of perjury.)
Porn, Approved for op ,onaI Use
Judiial Counrcil
of California

MC-025[Rer. Jury1.2W91

ATTACHMENT

to Judicial Council Form

Page
3 of
(Add pages as required)
,gww.courlflfo

ca gov

MC-025
SHORT TITLE:

CASE NJUMBER

Lane Bajardi. ct'al. v. Nancy PinIcuS, ci. at.

L-3723- 12
ATTACHMENT (Number); 3 (cont.)

(This Attachment may be used with any Judicial Council form.)

DOCUMENTS SUBPOENAED (cont.)

5.) Please produce the Following account holder/user details where possible: mailing addresses; residential
addresses business addresses; the actual address where the service is provided (such as telephone lines, DSL
or TI services); the user's primary e-mail address and an\, alternate email addresses, all Of the user's telephone
numbers or other user number or identi tier umber; and an), fax numbers associated with the user.
6.) Please produce a detailed record of every IP address that has been allocated to the above user/customer
since January 1,.2011, until the date ol'receipt of this request, together with the precise date and time that Such
IP addresses changed.
7.) Please produce Media Access Control address ("MAC address") for each connection/session and the agent
details for each user connection including browser and version, operating systemn and version, and any other
logged inlbormation.
EMAIL ACCOUNT INFORMATION REQUESTS
Please produce, for email accounts grafixavcenger666(gici ,iicom, any and all documents and/or in formation
relating to each account including, but not limited to:
1.) The First and last name or names given by the user or Subscriber when cstablishing the emnail account:
2.) All of the users' alternate email addresses, if applicable,
.3.) All physical and postal address inflormation for the ulser:
4,) All other contact information including, but not limited to. telephone numbers and Fax numbers:
5.) The Cellular phone number used to verify' the account by way of SMS text mnessage. if applicable:
6.) The details of any other mnethod, or medium used, in the process of verify'ing the user's identity or details:
7.) Any additional information that mnay assist in identifying the ISP of the email subscriber;,
8.) The connection logs information focr the above-mentioned email service:
9.) Any connections to the email account including the connection firomn which the account was first
established;
10.) The date, time and time zone for each connection or login to the email service by the Suibscriber:
11.) The date and timne for each disconnection or logzorrT or each connection/session:

(If the item that this Attachment concemns is made under penalty of perjury all statements in this
Attachment are made under penalty of perjury.)
Fain, Approved
for Opltonal Use
Judicial Councilof California
MC-025 [Rev. July1. 20091

ATTACHMENT
to Judicial Council Form___

Page

of

(Add pages as required)

rvuW.coOutllIo.C

gov

MC -025
SHORT TITLE:

CASE NUMBER

Lane Bajardi, et a]. v. Nancy Pincus. et al.

L-3723- 12
ATTACHMENT (Number).; 3

(cont.)

(This Attachment may be used with any Judicial Council form.)

DOCUMENTS SUBPOENAED (corn.)

12.) The originating IP address for each connection/session:
13.) If available, provide the agent details for each access including, browser and version. operating system and
version, and any other logged information for each conncction/scssimn
14-) If available, provide Media Access Control address (MAC address) for eacheconnection/session and
15,) If the user has any secondary email accounts or any other interactive or other services with you including
but not limited blogs, VoIP. photo albums, please provide all related identifying information and [P log details.
REQUESTS REGARDING OTHER GOGLE SERVICES
1.) Please provide all identifying and log infiormation as requested for the prod ucts/services described above
for anv' of the following services in use by the user:
a. www".voutubc.com/\\atch'.vgo'd-dHmil2eO'
Uploaded by kgardiner67
hittp://"ww.voutubc. coin/uscr/koardiiner67

I-Mar-12

b. ww,.w.youtube.comn/watch?v~jr88BoxbZZc Friday March 9, 2012

Uploaded by .1BL-3KINGS
hittp://wwwN.y'ouIte.COM/Luser/JBL3 KING S
C.wwwV,.)outube.comi/\watch'?Iv=isdpqLc-iewN 7-Apr- 12
Uploaded by Bellissimavidco
hlttp://'NWW.VOultube.COM/Luser/Bcllissimnavidco
d. wwwv.bloggcr com/profile/09277322207')13)098473
c. www.bloggcr.comn/pro file/ 14 87462 71795 32953 362
f. www.bloggcr.com/pro ile/1 12032306253287 19004
g. www.blogger. comn/orot-le/1 6859075045362730535

(If the item that this Attachment concerns is made under penalty of perjury, all statements in this
Attachment are made under penalty of perjury.)
Forn Apprnved
fo, OptionalUse
Judicial C.unct of Calhfomia
MC-025lRev. July 1,20091

Page=~ of

6ii

(Add pages as required)

ATTACH MENT
to Judicial Council Form

wwcuhkaa

MC-025
SORT TITLE:

CASE NUMBR;W

Lane Bajardi, et al. v. Nancy PiIcLIS. et al.

L-3723- 12
ATTACHMENT (Number):

(This Attachment may be used with any Judicial Council form.)

Attorneys for Plaintiffs Lane Bajardi, et al.

Amy D. Cox
2308 Dorchester Street West
Furlong, PA 18925
and
Whitney C. Gibson
VORYS SATER SEYMOUR & PEASE, LLP
30 1 East Fourth Street. Suite 3500
Great American Tower
Cincinnati. OH 45202

Attornecys for Defendants Nancy PincuIS, et al.

No appearance to date

(If the item that this Attachment concerns is made under penalty of pejury, all statements in this
Attachment are made under penalty of pedr]iy.)
Foon Appmo fowOpimal~ Use
JudicialCouncil of Caiiomna

MC-025 (Re. July 1.20091

ATTAC HMENT

to Judicial Council Form

Page

6-

of

61

(Add pages as required)

unw~o~euftOfoxgon