Mikhlyn et al v. Bove et al

Filing 88

Subpoena by Ana Bove. (Attachments: # 1 Subpoena 1, # 2 Subpoena 2, # 3 Subpoena 3, # 4 Subpoena 4, # 5 Subpoena 5, # 6 Subpoena 6, # 7 Subpoena 7) (Kogan, Boris)

Mikhlyn et al v. Bove et al

Doc. 88 Att. 1

Case 1:08-cv-03367-CPS-RER Document 88-2

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ------------------------------------X VADIM MIKHLYN, INGA MIKHLYN, and ABC ALL CONSULTING, INC. Plaintiffs, - against ANA BOVE, ANNA BOVE ANNA BOVE ANNA BOVE POLINA DOLGINOV, COMPANY, LLC, COLLECTIONS, INC., and EMBROIDERY SUPPLIES, INC.,

Case No. CV 08 3367

SUBPOENA DUCES TECUM

Defendants. -------------------------------------X ANA BOVE, ANNA BOVE COMPANY, LLC, and ANNA BOVE EMBROIDERY SUPPLIES, INC., Counter-Plaintiffs, - against VADIM MIKHLYN, INGA MIKHLYN, and ABC ALL CONSULTING, INC., Counter-Defendants. -----------------------------------X TO: Google, Inc. Attn: Legal Department 1600 Amphitheatre Pkwy Mountain View, CA 94043 YOU ARE COMMANDED, to produce and permit inspection and

copying of the following documents or objects at the place, date and time specified below: DOCUMENTS 1. Any and all emails or internet chats in connection with the subscriber of the email addresses [e-mail] and

Dockets.Justia.com

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[e-mail]. 2. Any and all emails or internet chats in connection with the following names: Full Name: Address: Full Name: Address: Full Name: Address: Full Name: Address: Full Name: Address: Full Name: Address: Tax ID No: VADIM MIKHLYN 2536 Harway Ave Brooklyn, New York 11214 VADIM MIKHLYN 6801 19th Ave, Suite #4P Brooklyn, New York 11204 INGA MIKHLYN 2536 Harway Ave Brooklyn, New York 11214 INGA MIKHLYN 6801 19th Ave, Suite #4P Brooklyn, New York 11204 ABC ALL CONSULTING, INC. 2536 Harway Ave Brooklyn, New York 11214 ABC ALL CONSULTING, INC. 6801 19th Ave, Suite #4P Brooklyn, New York 11204 13-4282767

from January 1, 2002 through the date of your response, at your institution. PLACE: U. S. District Court Eastern District of New York 225 Cadman Plaza East, Room 118 South Brooklyn, New York 11201 10:00am on October 15, 2009

DATE AND TIME:

Dated: Brooklyn, New York , 2009 September Ramon E. Reyes, Jr United States Magistrate Judge United States District Court 225 Cadman Plaza East Brooklyn, NY 11201

Case 1:08-cv-03367-CPS-RER Document 88-2

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I. INSTRUCTIONS a) In responding to this subpoena duces tecum, please furnish all documents in your possession, custody or control, regardless of where they may be located. To the extent that this request calls for what you believe to be documents subject to a claim of privilege, attorney work product, or material prepared for litigation, please provide a privilege log. Unless otherwise specified, the documents sought by this request are all those that were created or came into your possession, custody or control for the period of 2002 through the present.

b)

c)

II. DEFINITIONS 1. As used herein the terms "document" and "documents" mean any and all tangible things, whether handwritten, typed, printed, e-mailed, recorded, filmed, photostated, copied or reproduced in any way. The term "documents" shall also include any draft or version of a document and all copies which are not identical to the original; all modifications or additions to any document, whether or not such copies or drafts are specifically mentioned in particular requests; and any material recorded on verbal, graphic, computer, electronic, telecommunicative, or magnetic form, and any other form capable of being read, heard or otherwise understood. The terms "you" and "your" means belonging to Google, Inc., its affiliates, agents, servants, principals, partners, associates, employees, corporate officers, attorneys, representatives, investigators, experts, or consultants employed, retained or hired by or on their behalf, and all others who have acted, purported to act, or obtained information for or on their behalf. The term "relating to" means referring describing, evidencing, or constituting. to, concerning,

2.

3. 4. 5.

The singular shall include the plural and the plural shall include the singular. The words "and" and "or" shall be construed conjunctively to mean "and/or.". The word "any" shall be construed to mean "any and all" where the effect of such construction is to broaden the scope of the document request in question. The term "including" shall not be construed to limit the scope

6.

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of any document request; rather, it shall be construed as meaning "including, without limitation." 7. The term "person(s)" includes any natural person or any business, legal or governmental entity or association, and any subdivisions, instrumentalities and agencies thereof.