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8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
1/11
r
I Raines FeIdmanLLP
Lawyers
Beverly Hills
9720 Wilshire Boulevard
th
Floor
Beverly Hills California 90212
Irvine
18401 Von Karman Avenue Suite 360
Irvine California 92612
Main: 310.440.4100
www.raineslaw.com
Fax: 310.691.1238
esyverson@rpineslaw.com
May 3 2016
VI PERSON L DELIVERY
Custodian of Records
CT Corporation System
o
Glassdoor Inc.
818 W.
7th
Street Ste. 930
Los Angeles CA 90017
Re:
hilip J Layfield v Does 1 through 25 et al
Los Angeles Superior Court Case No BC618139
Dear Custodian of Records:
Enclosed is a Deposition Subpoena for Production of Business Records regarding
user information relevant to the above captioned case. The Subpoena is duly issued and
is being served upon you pursuant to the California Discovery Act.
Because the records requested must be authenticated I am also enclosing a form
Declaration of Custodian of Records that you may use for that purpose if your company
does not have its own declaration that is compliant with California Evidence Code
§ 1561 which requires such declarations to include a description of the records
produced and the mode of preparation.
Although the enclosed subpoena specifies production of records at our legal
document reproduction company you may instead make a direct production to our
office. Also I would be happy to provide you with electronic copies of any of the
8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
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8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
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SUBP 010
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and ed ess):
FOR COURT USE ONI.
V
_Erik S. Syverson (State Bar No. 221933)
RAINES FELDMAN LLP
9720 Wilshire Boulevard,
5 h
Floor
Beverly Hills, California 90212
TELEPHONE NO.:
(310) 440-4100
AX NO.:
(310) 765-7730
E-MAIL ADDRESS:
esyverson@rainesiaw.com
ATTORNEY FOR (Name):
Plaintiffs Philip J. Layfield and Layfield Barrett, APC.
SUPERIOR COURT
OF
CALIFORNIA COUNTY OF
Los Angeles
STREET ADDRESS:
111 North Hill Street
MAILINGADDRESS:
111 North Hill Street
CITYANDZIPCODE:
Los Angeles, California 90012
BRANCH NAME:
Central District
PLAINTIFF PETITIONER: Philip J. Layfield; Layfield Barrett, APC.
DEF ENDANT R ESPONDENT:
Does I through 25
DEPOSITION SUBPOENA
CASE
ER
8 39
FOR PRODUCTION OF BUSINESS RECORDS
THE PEOPLE O F THE STATE OF CALIFORNIA, TO
name, address, and telephone number of deponent, If known):
CT Corporation System,
o
Glassdoor,Inc. 818W.
7th
Street, Ste. 930, Los Angeles, California 90017
1. YOU ARE UIItKW
TO PIKUDU E THE
USINSS RECORDS
described In Item 3, as follows:
To
name of deposition officer):
ProLegal
On date):
May 24, 2016
t time):
10:00 a.m.
Locat ion address):
17921 Sky Park Circle, Suite C, Irvine, CA 92614
Do not release the requested records to the deposition officer prior to the date and time stated above.
D Q
by delivering a true, legible, and durable copy of the business records described in item 3, enclosed in a sealed Inner
wrapper with the t it le and number of the action, name of witness, and date of subpoena clearly writ ten on it, The inner
wrapper shal l then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposit ion off icer at the
address In Item 1.
by delivering a true, legible, and durable copy of the business records described In Item 3 to the deposit ion officer at the
witness s address, on receipt of payment in cash or by check of th e reasonable costs of preparing the copy, as determined
under Evidence Code sect ion 1563(b).
y making th e original business records described in I tem 3 avai lable for inspection at your business address by the
at torney s representat ive and permit t ing copying at your business address under reasonable condit ions during normal
business hours,
2. The records are to be produced by the date and time shown in Item I but not sooner than
20 days
after the Issuance of the
deposition subpoena, or 15
days
after seivice, whichever date is later). Reasonable costs of locating records, making them
available or copying them, and postage, if any, are recoverable
as set
forth in Evidence Code section 1563 b). The records shall be
accompanied by an affidavit of the custodian or other qualified witness pursuant to Evidence Code section 1561,
3. The records to be produce d are described as fol lows
if electronically stored information/s demanded, the form or
forms in which
each
type of information is to be produced may be specified):
Cont inued on At tachment 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 O BJECTION HAS BEEN
SERVED ON YOU A COURT ORDER OR AGREEMENT OF THE PARTIES WITNESSES
ND
CONSUMER OR EMPLOYEE
AFFECTED MUST BE OBTAINED BEFORE
YOU ARE REQUIRED TO
PRODUCE CONSUMER OR EMPLOYEE RECORDS
DISOBEDIENCE OF THIS SUBPOENA MA Y BE PUNISHED AS CONTEMPT BY THIS COURT YOU WILL ALSO BE LIABLE
OR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM
AILURE TO OBEY.
Date issued: May 2, 2016
REO
Erik S. Syverson
(TYPE OR PRINT NAME)
PERSON ISSUING SUBPOENA)
Attorney for Plaintiffs
(TITLE)
(Proof of service on reverse)
age 1*f 2
Form Adopted for Mendatoi-y Use
EPOSITION SUBPOENA FOR PRODUCTION
ode of Civil Procedure,
6 §
2020410-2020.440:
Judidml CouncIl of California
SUOP-OlO [Rev. January 1,20121
F BUSINESS RECORDS
overnrnenl Code. § 6809,1
avew.courfs.ca.gov
8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
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SUBP 01O
PLAINTIFF/PETITIONER:
Philip J. Layfleld and Layfield & Barrett APC,
ASE NUMBER:
C618139
DEFENDANT/RESPONDENT:
Does 1 through 25
PROOF OF SERVICE OF DEPOSITION SUBPOENA FOR
PRODUCTION OF BUSINESS RECORDS
1
I served this
Deposition Subpoena for Production of Business Records
by personally delivering a CO PY to the person served
as follows:
Person served
name):
Address where served:
Date of delivery:
Time of delivery:
(1)
itness fees were paid.
Amount
...............................
$
(2)
0
Copying fees were paid.
Amount
. ................................
Fee for service' .................................. $
2. I received this subpoena for service on
date):
3. Person serving:
Not a registered California process server.
0
California sheriff or marshal.
Registered California process server.
0
Employee or independent contractor of a registered California process server.
El
Exempt from registration under Business and Professions Code section 22350(b).
Registered professional photocopier.
Exempt from registration under Business and Professions Code section 22451.
Name, address, telephone number, and, if applicable, county of registration and number:
I doclare under penalty of perjury under the laws of the State of
For California sheriff or marshal use only)
California that the foregoing is true and correct, certify that the foregoing is true and correct.
Date:
ate:
(SIGNATURE)
SIGNATURE)
SUBP.010 tRov. .kinuary 1. 20121
EPOSITION SUBPOENA FOR PRODUCTION
OF BUSINESS RECORDS
Aneiliii LeaINeI, Ii,c.
fQ uW,rIFIow.com
8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
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TTACHMENT 3
2
O DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS
3
EFINITIONS AND INSTRUCTIONS
4
.
DOCUMENT or DOCUMENTS refers to writings as defined by California
5
vidence Code § 250 and includes, but is not limited to, the original and all drafts of all written or
6
raphic matter, however produced or reproduced, of any kind of description, and all copies thereof
7
which are different from the original (whether different by interlineation, receipt stamp, notation,
8
ndication of copies sent or received, or otherwise), whether printed or recorded electronically or
9
magnetically or reproduced by hand.
10
.
he term PERSON shall mean and include all natural persons, as well as
orporations, partnerships, and other business entities.
12
.
he phrases RELATE TO, RELATING TO, or RELATED TO as used
13
herein, shall mean, in whole or in part, constituting, containing, embodying, reflecting, regarding
14
referring to, concerning, identifying, stating, implying, evidencing, supporting, documenting,
15
memorializing, mentioning, or in any way relating or pertaining to, the subject designated.
16
.
he terms ANY, EACH, or ALL shall be read to be all inclusive and to
17
require the production of each and every DOCUMENT responsive to a particular request for
18
production in which such term appears.
19
.
he terms YOU AND YOUR as used herein, shall mean and refer to
20
Glassdoor, Inc., the entity that owns the website www.glassdoor.com
, and YOUR present and
21
former agents, representatives, employees, attorneys, accountants, auditors, investigators, and all
22
other person(s) acting or purporting to act on YOUR behalf.
23
.
he phrase IDENTIFYING INFORMATION as used herein, shall mean any
24
information that can be used to identify individuals, including, but not limited to, names,
5
addresses, telephone numbers, email addresses, usemames, Internet Protocol ( IP ) addresses,
26
erver log entries, methods of payment, credit card information, billing records, and any Inten1et
27
Service Providers ( ISP ) associated with these individuals.
28
ATTACHMENT 3
8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
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1
.
s used herein, the connectives
4
nd or shall be construed conjunctively or
2
disjunctively, as necessary, to make the requests inclusive rather than exclusive to bring within the
3
cope of the discovery request all responses that might otherwise be construed to be outside of its
4
scope.
. s used herein, any and all references to the singular in any of these requests shall
6
also include a reference to the plural, and any and all references to the plural shall include a
7
reference to the singular.
8
OCUMENT REOUESTS
9
REQUEST FOR PRODUCTION NO. :
1
NY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
11
describe, or refer to IDENTIFYING INFORMATION RELATED TO the PERSON(S) who
12
authored, submitted for publication or posted to YOUR website, www.glassdoor.com
, the review
13
ated March 28, 2016 and entitled Bad place to work (this company just changed its name)
14
esearch Layfield & Wallace , that appeared at https ://www.glassdoor. comlReviews/Layfield-
15
nd-Barrett-Reviews-Eli
50756 htm
16
REQUEST FOR PRODUCTION NO.2:
17
NY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
18
describe, or refer to IDENTIFYING INFORMATION RELATED TO the PERSON(S) who
19
authored, submitted for publication or posted to YOUR website, www.glassdoor.com
, the review
2
dated December 4, 2015 and entitled Deceptive, Unethical, Poorly Managed, No Sense of
21
irection , that appeared at https ://www.glassdoor.cornlReviews/Layfield-and-Wall ace-Reviews-
22
l 00461 8 htrn
23
REQUEST FOR PRODUCTION NO.3:
24
NY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
25
describe, or refer to IDENTIFYING INFORMATION RELATED TO the PERSON(S) who
26
authored, submitted for publication or posted to YOUR website, www.glassdoor.com
, the review
27
dated December 3, 2015 and entitled You will HATE working here - Please read all the
28
ATTACHMENT 3
8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
7/11
1
eviews , that appeared at https://www.glassdoor. comlReviews/Layfield-and-Wallace-Reviews-
2
E100461 8.htm.
3
REQUEST FOR PRODUCTION NO 4:
4
NY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
5
describe, or refer to IDENTIFYING INFORMATION RELATED TO the PERSON(S) who
6
authored, submitted for publication or posted to YOUR website, www.glassdoor.com
, the review
7
dated October 9, 2015 and entitled Working Here is Psychological Torture , that appeared at
8
ttps ://www.glassdoor. comlReviews/Layfield-and-Wallace-Reviews-E 1004618 .htm
9
REQUEST FOR PRODUCTION NO 5:
1
NY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
11
describe, or refer to IDENTIFYING INFORMATION RELATED TO the PERSON(S) who
12
authored, submitted for publication or posted to YOUR website, www.glassdoor.com
, the review
13
dated September 27, 2015 and entitled New Admitees Beware , that appeared at
14
ttps ://www.glassdoor.comlReviews/Layfield-and-Wallace-Reviews-E 1004618 .htm
15
REQUEST FOR PRODUCTION NO 6:
16
NY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
17
describe, or refer to IDENTIFYING INFORMATION RELATED TO the PERSON(S) who
18
authored, submitted for publication or posted to YOUR website, www.glassdoor.com
, the review
19
dated September 7, 2015 and entitled For the love of God, do NOT work here , that appeared at
20
ttps ://w ww.glassdoor.cornlReviews/Layfield-and-Wall ace-Reviews-E 100461 8_P2 .htrn.
21
REQUEST FOR PRODUCTION NO 7:
22
NY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
23
describe, or refer to IDENTIFYING INFORMATION RELATED TO the PERSON(S) who
24
authored, submitted for publication or posted to YOUR website, www.glassdoor.com
, the review
5
ated August 3, 2015and entitled Anyone who give this place a full rating has literally just started
26
orking there , that appeared at https ://www. glassdoor.cornlReviews/Layfield-and-Wallace-
27
eviews-E100461 8P2.htrn.
28
ATTACHMENT 3
8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
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8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
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1 REQUEST FOR PRODUCTION NO 12:
2
NY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
3
describe, or refer to IDENTIFYING INFORMATION RELATED TO the PERSON(S) who
4
authored, submitted for publication or posted to YOUR website, www.glassdoor.com
, the review
5 dated April 2, 2016 and entitled Don't let the name change fool you, read the reviews for
6
Layfield & Wallace. This is Phil Pesin's way of 'starting fresh , that appeared at
7
ttps://www.glassdoor.comlReviews/Layfield-and-Barrett-Reviews-E
11 50756 htm
8
9
1
11
12
13
14
15
16
17
18
19
2
21
22
23
24
25
26
27
28
TTACHMENT 3
8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
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2
3
4
6
7
8
9
10
11 PHILIP J. LAYFIELD, an individual and
LAYFIELD BARRETT, APC., a California
12
professional corporation,
13
laintiffs,
14 v.
15
DOES 1 through 25, inclusive,
16
efendants.
17
8
19
20
21
22
23
24
25
26
27
28
CASE NO. BC618139
[Unlimited Jurisdiction]
DECLARATION OF CUSTODIAN OF
RECORDS FOR AUTOMATTIC INC.
PURSUANT TO CALIFORNIA EVIDENCE
CODE
§
1561
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
DECLARATION OF CUSTODIAN OF RECORDS
8/17/2019 Philip J. Layfield and Layfield & Barrett, APC Subpoena
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1
ECL R TION OF CUSTODI N OF RECORDS
2
eclare and state as follows:
3
.
am the duly authorized custodian of records for Glassdoor, Inc., and I have
4
authority to certify such records.
.
y business address is
6
.
was served with a civil subpoena duces tecum in the above-captioned proceeding
8
(the Subpoena ).
9
.
he copies produced in response to the Subpoena are true and correct copies of all
1 ecords requested in the Subpoena, which are in my possession as custodian of records.
11
he original records from which the accompanying copies were made have been
12
repared by
in the ordinary course of business at or
13
ear the times of the acts, conditions or events recorded therein.
14
. he records are identified as follows:
15
16
17
18 he following is a description of the mode of preparation:
19
2
21
22
23
declare under penalty of perjury under the laws of the State of California that the
24
oregoing is true and correct and that this declaration was executed on 2016, at
25
26
27
eclarant
28
DECLARAT ION OF CUSTODIAN OF RECORDS
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