My subpoena to iContact in connection with my litigation against America Resources Exploration, Inc. (AREN), requiring all documents in connection with Finest Penny Stock's (and sister newsletters) accounts.
My subpoena to iContact in connection with my litigation against America Resources Exploration, Inc. (AREN), requiring all documents in connection with Finest Penny Stock's (and sister newsletters) accounts.
My subpoena to iContact in connection with my litigation against America Resources Exploration, Inc. (AREN), requiring all documents in connection with Finest Penny Stock's (and sister newsletters) accounts.
SUBP-010
“ATORNEY GR PARTY WATHOUT ATTORNEY Pane, Sn Barra nd ae
[George Sharp
$628 Del Mar Heights Road, #820
a ee OFS 08-4455 rcv.
ew ooress george @clippercp.com
somevracen, Fe BIO Petar
‘SUPERIOR COURT OF CALIFORNIA, couNTY OF San Diego
secrsensess 330 W. Broadway
cmvwozecoe San Diego, CA 92101
sewcrmae Central Division
puunmiFFPetiTioner: George Sharp
DEFENDANTmESPONDENT: American Resources Exploration, Inc.
DEPOSITION SUBPOENA eee
FOR PRODUCTION OF BUSINESS RECORDS 37-2015-00028270-CU
‘THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, if known):
Custodian of Records for iContact, LLC 2450 Perimeter Park Park Dr, Ste 105, Morrisville, NC 27560
1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item 3, as follows:
To (name of depostion oficen; Victoria Loera
(On (dete) : October 9, 2015 ‘At (ime): 10:00am
Location (address): 13681 Newport Avenue, Suite 8-608, Tustin, California 92780
Do not rolease the requested records to the deposition officer prior to the date and time stated above.
'&. L271 by delivering a tue, legible, and durable copy of the business records described in item 3, enclosed in a sealed inner
‘wrapper with the ttle and numberof 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
adéress in item 1
v, (] by delivering a true, leable, and durable copy of the business records described in item 3 to the deposition officer at the
‘witness'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(0).
c. [1] by making the original business records descrived in item 3 available for inspection at your business address by the
attorney's representative and permitting copying at your business address under reasonable conditions during normal
business hours.
‘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 after service, whichever date is late). Reasonable costs of locating records, making them
‘available or copying them, and postage, if any, are recoverable as set fort in Evidence Code section 1563(b). The records shall be
‘accompanied by an affidavit of the custodian or other qualfed witness pursuant to Evidence Code section 1561
3, The records to be produced are described as follows (if electronically stored information is demanded, the form or
forms in which each type of information is to be produced may be specified):
[21 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
HE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
Date issued:
Michael Roddy pA QO
vee oR PRN E ‘BIGRATURE OF PERSON SUNG
(Proot of sence on reverse) er papers
eee care far DEPOSITION SUBPOENA FOR PRODUCTION Cole ot a roe, 200 0-020
eose neers Ie, ‘OF BUSINESS RECORDSSharp v. American Resources Exploration, Inc.
CASE NO. 37-2015-0028270-CU-NP
ATTACHMENT 3
Deposition Subpoena for Production of Business Records to
Custodian of Records of iContact, LLC
2450 Perimeter Park Drive, Suite 105, Morrisville, North Carolina 27560
. 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 “Info@smartstockwinners.com”.
|. All documents which show any predecessor return email addresses for the
account currently operated under the return email address
“Info@smartstockwinners.com”.
. All account opening documents for your client that operates under the
return email address “Info@smartstockwinners.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 “Info@smartstockwinners.com” or predecessor email
addresses.
. All documents which show payments received by you for the account
operated with the return email address “Info@smartstockwinners.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 “Info@smartstockwinners.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
“Info@smartstockwinners.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
“Info@smartstockwinners.com” or predecessor email addresses.
}. All documents, including but not limited to electronic Documents, showing
the names, addresses. phone numbers and other contact information ofthe entities and/or persons for whom you disseminate emails on behalf of
the return email address “Info@finestpennystocks.com ”.
10. All documents which show any predecessor return email addresses for the
account currently operated under the return email address
“Info@finestpennystocks.com ”.
11. All account opening documents for your client that operates under the
return email address “Info@finestpennystocks.com ” or predecessor email
addresses.
12. 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 “Info@finestpennystocks.com ” or predecessor email
addresses.
13. All documents which show payments received by you for the account
operated with the return email address “Info@finestpennystocks.com ” or
predecessor email addresses.
14. 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 “Info@finestpennystocks.com ” or predecessor email addresses.
15. 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
“Info@finestpennystocks.com ” or predecessor email addresses.
16. 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
“Info@ finestpennystocks.com ” or predecessor email addresses.
17. 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 “Info@bestamericanstocks.com”.
18, All documents which show any predecessor return email addresses for the
account currently operated under the return email address
“Info@bestamericanstocks.com”.
19. All account opening documents for your client that operates under the
return email address “Info@bestamericanstocks.com” or predecessor email
addresses.20. 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 “Info@bestamericanstocks.com” or predecessor email
addresses.
21. All documents which show payments received by you for the account
operated with the return email address “Info@bestamericanstocks.com” or
predecessor email addresses.
22. 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 “Info@bestamericanstocks.com” or predecessor email addresses.
23. 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
“Info@bestamericanstocks.com” or predecessor email addresses.
24. 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
“Info@bestamericanstocks.com” or predecessor email addresses.TORE RPT TOUT ATTORNEY Ro ae aro Fon couarint omy
\George Sharp
3525 Del Mar Heights Road, #620
San Diego, CA 92130
seemone no.310-498-4455 4H ote
sa s00ness rge@clippercp.com
arromevror aane:Jn Propria Persona
‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Dicgo
seer sooness330 W Broadway
swan soos
env ano.2p cone San Diego, CA 92101
euncinwe Central Division,
PETMONERPLANTIFF OFOTE€ STP
RESPONDENTDEFENDANT-American Resources Exploration, Inc.
CASE NIMES
37-2015-00028270-CU-NP-CTL
(Do not use this Proof of Service to show service of a Summons and Complaint)
1, | am 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.
PROOF OF SERVICE BY FIRST-CLASS MAIL—CIVIL
2. Myrestenes attains sen
3955 Del Mar Heights Road, #620, San Diego, CA 92130
3, On (date):August 31,2015 I malled from (city and state)‘San Diego, California
the following documents (specify):
Deposition Subpoena for Production of Business Records
Attachment 3
(The documents are ists in the Attachment fo Prot of Service by Fit-Cless Mait—Civi (Documents Servea)
omPos- 2300)
4, | served the documents by enclosing hem in an envelope and (check one)
1. LZ] depositing the sealed envelope with the United States Postal Service with the postage fully prepaid.
.. [—] placing the envelope for collection and mailing following our ordinary business practices. | am readily familiar with this
business's practice for collecting and processing coresponcence for maling, On the same day that cmespondence is
placed for colecon and mating, I's Geposted inthe ordinary course of business wth he United States Postal Service in
a sealed envelope with postage fully prepaid.
5, The envelope was adiressed and maled a flows
‘a, Name of person served:Custodian of Records, iContact, LLC
Address of person served
2450 Perimeter Park Drive, Suite 105, Morrisville, NC 27560
[The name and address of each person to whom I mailed the documents Is listed in the Attachment to Proof of Service
by First-Class MaitChuil (Persons Served) (POS-030(P)).
| declare under penalty of perjury under the laws of the State of Caffomi
Date: August 31, 2015
Qe Is true and correct
»
eo PNT RANE GF PERSON CONRIETNG TS FOR ‘wT RE OPO COMPETING Tee Fa
‘Seid Exot rey PROOF OF SERVICE BY FIRST-CLASS MAIL—CIVIL Sie oe rnags a
ee (Proot of Service) one
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