Philip J. Layfield and Layfield & Barrett, APC Subpoena
Philip J. Layfield and Layfield & Barrett, APC Subpoena
Philip J. Layfield and Layfield & Barrett, APC Subpoena
Beverly Hills
9720 Wilshire Boulevard, 5th Floor
Beverly Hills, California 90212
I Raines FeIdmanLLP
Lawyers
Irvine
18401 Von Karman Avenue, Suite 360
Irvine, California 92612
Main: 310.440.4100
www.raineslaw.com
Fax: 310.691.1238
[email protected]
May 3, 2016
VIA PERSONAL DELIVERY
Custodian of Records
CT Corporation System
do Glassdoor, Inc.
818 W. 7th Street, Ste. 930
Los Angeles, CA 90017
Re:
Custodian of Records
May 3, 2016
Page 2
Sincerely,
f4 ~
Erik S. Syverson
of RAIN ES FELDMAN LLP
Enclosed:
Deposition Subpoena for Production of Business Records;
Attachment "3" to Deposition Subpoena for Production of Business Records;
Declaration of Custodian of Records
SUBP-010
FOR COURT USE ONI.V
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and ed&ess):
DEPOSITION SUBPOENA
FOR PRODUCTION OF BUSINESS RECORDS
CASE
MER
8 39
THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, If known):
CT Corporation System, do Glassdoor,Inc. 818W. 7th Street, Ste. 930, Los Angeles, California 90017
1. YOU ARE UIItKW TO PIKUDUCE THE
DQ by delivering a true, legible, and durable copy of the business records described in item 3, enclosed in a sealed Inner
wrapper with the title 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.
by delivering a true, legible, 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 of the reasonable costs of preparing the copy, as determined
under Evidence Code section 1563(b).
0 by making the original business records described 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,
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 produced are described as follows (if electronically stored information/s demanded, the form or
forms in which each type of information is to be produced may be specified):
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
FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM
FAILURE TO OBEY.
I
Date issued: May 2, 2016
Erik S. Syverson
(TYPE OR PRINT NAME)
Page 1*f 2
Code of Civil Procedure, 6 2020410-2020.440:
Governrnenl Code. 6809,1
avew.courfs.ca.gov
SUBP-01O
PLAINTIFF/PETITIONER: Philip J. Layfleld and Layfield & Barrett APC,
CASE NUMBER:
BC618139
Date of delivery:
Time of delivery:
(1)
(2)
0
El
Date:
Date:
(SIGNATURE)
(SIGNATURE)
ATTACHMENT "3"
4
5
6
1.
Evidence Code 250 and includes, but is not limited to, the original and all drafts of all written or
graphic 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 indication of copies sent or received, or otherwise), whether printed or recorded electronically or
9 magnetically or reproduced by hand.
10
2.
The term "PERSON" shall mean and include all natural persons, as well as
11
12
13
14
15
16
17
herein, shall mean, in whole or in part, constituting, containing, embodying, reflecting, regarding
referring to, concerning, identifying, stating, implying, evidencing, supporting, documenting,
memorializing, mentioning, or in any way relating or pertaining to, the subject designated.
4.
The terms "ANY," "EACH," or "ALL" shall be read to be all inclusive and to
require the production of each and every DOCUMENT responsive to a particular request for
The terms "YOU" AND "YOUR" as used herein, shall mean and refer to
former agents, representatives, employees, attorneys, accountants, auditors, investigators, and all
22
23
24
25
26
27
information that can be used to identify individuals, including, but not limited to, names,
addresses, telephone numbers, email addresses, usemames, Internet Protocol ("IP") addresses,
server log entries, methods of payment, credit card information, billing records, and any Inten1et
Service Providers ("ISP") associated with these individuals.
28
ATTACHMENT "3"
7.
As used herein, the connectives "4" and "or" shall be construed conjunctively or
2 disjunctively, as necessary, to make the requests inclusive rather than exclusive to bring within the
3 scope of the discovery request all responses that might otherwise be construed to be outside of its
4 scope.
5
8.
As 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.
DOCUMENT REOUESTS
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ATTACHMENT "3"
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ATTACHMENT "3"
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ANY and ALL DOCUMENTS in YOUR possession, custody, or control, that state, list,
ATTACHMENT "3"
6 Layfield & Wallace. This is Phil Pesin's way of 'starting fresh", that appeared at
7 https://www.glassdoor.comlReviews/Layfield-and-Barrett-Reviews-E 11 50756.htm.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
ATTACHMENT "3"
1
2
3
4
5
6
7
8
10
11 PHILIP J. LAYFIELD, an individual and
LAYFIELD & BARRETT, APC., a California
professional
corporation,
12
13
[Unlimited Jurisdiction]
Plaintiffs,
14 v.
15 DOES 1 through 25, inclusive,
16
DECLARATION OF CUSTODIAN OF
RECORDS FOR AUTOMATTIC, INC.,
PURSUANT TO CALIFORNIA EVIDENCE
CODE 1561
Defendants.
17
18
19
20
21
22
23
24
25
26
27
28
DECLARATION OF CUSTODIAN OF RECORDS
1
2
3
I am the duly authorized custodian of records for Glassdoor, Inc., and I have
2.
My business address is
3.
I was served with a civil subpoena duces tecum in the above-captioned proceeding
6
7
8 (the "Subpoena").
9
4.
The copies produced in response to the Subpoena are true and correct copies of all
5.
The original records from which the accompanying copies were made have been
12 prepared by
6.
7.
15
16
17
18
19
20
21
22
23
I declare under penalty of perjury under the laws of the State of California that the
24 foregoing is true and correct and that this declaration was executed on
25
26
27
Declarant
28
DECLARATION OF CUSTODIAN OF RECORDS
, 2016, at