IN THE CIRCUIT COURT FOR THE THIRD JUDICIAL CIRCUIT IN AND FOR MADISON COUNTY, FLORIDA CABOODLE RANCH,

INC AND CRAIG GRANT, Plaintiffs, vs. CAROLYN CAMP LOGAN, GARY L. CONLEY, AND PAMELA JONASSON, Defendants. / DEFENDANT GARY CONLEYS FIRST REQUEST TO PRODUCE TO PLAINTIFFS Defendant, GARY L. CONLEY (hereinafter Defendant), by and through the undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, requests that Plaintiffs CABOODLE RANCH, INC. and CRAIG GRANT (hereinafter Plaintiffs), produce the documents described below within thirty(30) days of the date hereof at the offices of Sellers, Taylor & Morrison, P.A., 108 West Howard Street, Live Oak, FL 32064, or at another time and place mutually agreeable to counsel. INSTRUCTIONS 1. In the event that any documents or things the production of which is requested herein are withheld under a claim of privilege, please provide the following information with respect to each such document or thing: (a) (b) the type of document or thing, its general subject matter and the place and approximate date it was prepared or created; the name and title of each person who prepared or created the document or thing and the name and title of each other person who has received or examined the document or thing or a copy thereof; 1

CASE NO.: 10-589-CA

(d) (d)

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the type of privilege claimed; a statement of the circumstances which bear on whether or not the claim of privilege is appropriate and whether the privilege that is claimed should extend to all or only to part of the document or thing; and the numbers of each specification (Request to Produce contained herein) to which the document or thing otherwise would be responsive.

2.

In the event that any documents or things the production of which is requested herein are withheld under an objection, please provide the following information with respect to each such document or thing and respond to such request to the extent to which there is no objection: (a) (b) the type of document or thing, its general subject matter and the place and approximate date it was prepared or created; the name and title of each person who prepared or created the document or thing and the name and title of each other person who has received or examined the document or thing or a copy thereof; the type or nature of the objection asserted; a statement of the specific grounds for any asserted objection; and the numbers of each specification (Request to Produce contained herein) to which the document or thing otherwise would be responsive.

(d) (d) (e)

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If Plaintiffs maintain that any of the documents or things requested by a request for production of documents contained herein are not within their possession, identify each person who has possession of the documents or things. If Plaintiffs maintain that any document or thing that is requested herein has been destroyed, set forth the contents of the documents or things, the date of such destruction. the name of the person who authorized or directed such destruction, and the numbers of each specification (Request to Produce contained herein) to which the destroyed document(s) or thing(s) would otherwise be responsive. The requested documents should be produced separately in response to each numbered paragraph of the request or, in the alternative, the corresponding bates stamp or other identifying number given each document should be provided in response to each numbered paragraph of the request. This request for documents is intended to obtain information not merely within your possession but obtainable by you, including, but not limited to, information in the possession of your attorney, employees, volunteers, directors, board members, agents, investigators, insurance carriers and their representatives.

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Unless otherwise noted, the relevant time period for these requests shall be January 1, 2003 to the present.

DEFINITIONS 1. The term Plaintiffs shall mean Plaintiffs, CABOODLE RANCH, INC. and/or CRAIG GRANT, and any present or former agent, independent contractor, attorney; any present or former related companies and/or non-profit corporations, divisions, subsidiaries, and affiliates; all present or former officers, directors, board members, employees, and/or volunteers of Caboodle Ranch, Inc. and/or Craig Grant and of its related companies and/or non-profit corporations, divisions, subsidiaries and affiliates; and present or former representatives, experts, investigators, or insurers or any other person or entity acting for, or on behalf of, or under the authority or control of Caboodle Ranch, Inc. and/or Craig Grant. The terms Defendant shall mean Defendant, GARY CONLEY, and his agents, attorneys or any person(s) acting on Defendants behalf or at his direction or request in any manner relating to the issues, events, transaction and pleading in this civil action. The term you, your, yours, and its shall mean Plaintiffs Caboodle Ranch, Inc. and/or Craig Grant, as defined in paragraph 1 above. As used in this Request for Production of Documents, the term Document shall be construed in the broadest possible sense and includes, without limitation, any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processes or transcribed, including originals and all nonidentical copies and drafts, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, any printed, written, recorded, taped, electronic, graphic, or other tangible matter from whatever source, however produced or reproduced, whether in draft form or otherwise, whether sent or received or neither, including the original, all amendments and addenda and any nonidentical copy (whether different from the original because of notes made on or attached to such copy or otherwise) of all writings, correspondence, letters, telegrams, telex communications, cables, notes, notations, papers, newsletters, memoranda, interoffice communications, electronic mail, releases, agreements, contracts, books, pamphlets, studies, minutes of meetings, recordings or other memorials of any type of personal or telephone conversations, meetings, conferences (including, but not limited to, telephone bills and long distance charge slips), reports, analyses, evaluations, estimates, projections, forecasts, receipts, statements, accounts, video tapes, audio tapes, books of account, diaries, journals, calendars, desk pads, drawings, appointment books, stenographers notebooks, transcripts, ledgers, registers, worksheets, statistical records, cost sheets, summaries, lists, tabulations, digests, canceled or uncancelled checks or drafts, account ledgers, bank statements, vouchers, charge slips, invoices, purchase orders, hotel charges, accountants reports, financial statements, newspapers, periodical 3

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or magazine material, compact disks (CDs), DVDs, web pages, electronic media, and any material underlying, supporting, or used in the preparation of any documents. The term Document also means all computer records, data and information of whatever kind whether printed out or stored on or retrievable from any floppy diskette, compact diskette, magnetic tape, optical or magnetic-optical disk, hard drive or rapid access memory, including without limitation, all back-up copies, undeleted data, and dormant or remnant files. 5. Person or persons as used herein means all individuals and entities, including all natural persons, corporations, partnerships, ventures or other business associations, societies, associations-in-fact, all federal, foreign, state, local or other governmental entities, and all legal entities, including all members, officers, employees, agents, representatives, attorneys, successors, predecessors, assigns, divisions, affiliates and subsidiaries. Knowledge means information derived from any source, including hearsay knowledge. Relates to, relating to, pertains to, and pertaining to shall mean embodying, concerning, respecting, referring to, pertaining to, summarizing, digesting, reflecting, tending to establish, delegating from, commenting on, evidencing, comprising, containing, identifying, stating, responding or disagreeing with, showing, describing, analyzing, representing, constituting or including. Communications shall mean all written communications between two or more persons contained in any documents, or oral communications, including telephone communications, personal conferences, meetings or otherwise, between two or more persons. Concern, concerning or concerns shall mean relating to, referring to, constituting, comprising, containing, setting forth, showing, disclosing, describing, explaining, summarizing, mentioning, or in any way referencing, directly or indirectly. And and or shall also be construed either disjunctively or conjunctively as necessary to bring within the scope of this request all documents that might otherwise be construed to be outside its scope. Whenever the term all is used herein, it shall also be construed to mean any and each, and vice-versa. Whenever the term including is used herein, it shall be construed to mean including, but not limited to. The use of the singular shall also be taken to include the plural, and vice-versa, so as to bring within this request documents that might otherwise be excluded.

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Whenever a verb is used in one tense it shall also be taken to include all other tenses, so as to bring within this request documents that might otherwise be excluded. Agreement means any agreement, contract, understanding, or other type of agreement, formal or informal, oral or written, direct or indirect, tacit or express, between two or more persons, and includes within its term any appendix, exhibit, or other item appended or attached to the agreement. Cat and cats shall mean and/or refer to any felis catus/F. catus, also known as the domestic cat or housecat, including but not limited to any breed, subspecies, and/or distinct phenotype thereof, without regard to whether pseudo-wildcat, feral, stray, semiferal, pet, or pedigree. Occupy and occupied shall be construed to mean to take up, to take or hold possession or control of, to reside in as an owner or tenant, to use, and/or to make use of. All other terms shall be given their plain, ordinary meaning, unless indicated otherwise in the interrogatory. Terms subject to more than one interpretation shall be given their broadest possible meaning.

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DOCUMENTS TO BE PRODUCED 1. All e-mail or electronic communications in the possession, custody, or control of Plaintiffs, it agents, employees, volunteers, officers or directors, that relate, in any way, to Defendant and/or any cat owned or cared for at any time by Defendant and/or any subject matter of the instant litigation, without regard to whether the email or electronic communication was generated internally between Plaintiffs agents, employees, volunteers, officers or directors, between Plaintiffs and Defendant, or between Plaintiffs and a third-party, or an e-mail or electronic communication copied or forwarded to Plaintiffs by Defendant or a third party. 2. All documents of every description that relate in any way to communications between Plaintiffs and any party to the instant litigation, third-party individual, or

third-party entity concerning the subject matter of any claim or counter-claim contained in the instant lawsuit. 3. All documents, of every description, relating in any way to any and all cats owned and/or cared for by the Defendant, which were entrusted to the care of Plaintiffs on or about October 2010. 4. All documents of every description, which support the claims made by Plaintiffs in this action. 5. All documents, of any description, provided by Plaintiffs, its agents, employees, volunteers, officers or directors, to Defendant that relate in any way to the subject matter of any claim or counter-claim in this action. 6. All documents, of any description, provided by Defendant, to Plaintiffs, its agents, employees, volunteers, officers or directors, which relate in any way to the subject matter of any claim or counter-claim in this action. 7. All documents, of any description, evidencing, relating to and/or concerning any and all donations of any description, regardless of the nature of the donation (i.e. whether monetary, goods, real property, personal property, etc.), made to and/or received by Plaintiffs. 8. All documents, of any description, relating to and/or concerning any and all individuals, entities and/or third parties who owned, possessed, and/or cared for any cat and/or cats that thereafter came to be under the care, control and/or possession of Plaintiffs and/or came to be located, either temporarily or permanently, on property in Madison County, Florida owned, leased, rented, or otherwise occupied by Plaintiffs, regardless of whether the cat or cats were left 6

with, donated to, re-homed with, adopted to, placed with, sent to, brought to, or in any other way placed in the care, control, or possession of Plaintiffs or in these or any other way came to be located on property in Madison County, Florida owned, leased, rented, or otherwise occupied by Plaintiffs. 9. All documents, of any description, relating to and/or concerning any and all cats that came to be under the care, control and/or possession of Plaintiffs and/or came to be located, either temporarily or permanently, on property in Madison County, Florida owned, leased, rented, or otherwise occupied by Plaintiffs, regardless of whether the cat or cats were left with, donated to, re-homed with, adopted to, placed with, sent to, brought to, or in any other way placed in the care, control, or possession of Plaintiffs or in these or any other way came to be located on property in Madison County, Florida owned, leased, rented, or otherwise occupied by Plaintiffs. 10. Any and all documents relating to and/or concerning veterinary, medical, wellbeing and/or health care services and/or products of any description that were provided to and/or received by any cat, whether by Plaintiffs or any third party, while located on property owned, leased, rented, or otherwise occupied by Plaintiffs and/or while otherwise under the care, control and/or possession of Plaintiffs in any way, including but not limited to, veterinary records, medical records, medication documentation, treatment documentation, receipts, and files. 11. Any and all documents pertaining to any media coverage, including but not limited to any and all news articles, interviews, radio coverage, television

coverage, print publications/coverage, online/electronic media coverage, relating to and/or concerning any of the following: a) b) Plaintiffs; Plaintiffs operation of and/or involvement with any cat sanctuary or other non-profit organization, including but not limited to Caboodle Ranch, Inc.; c) any business, corporation, non-profit, and/or organization owned, run by, or in which plaintiffs are otherwise involved; d) any cat or cats owned, possessed, under the care of, and/or otherwise located on property owned, lease, rented, or occupied by Plaintiffs; e) the subject matter of any claim or defense in the instant lawsuit;

By means of example, but not limitation, any and all documents relating to Plaintiffs appearing on and/or being shown on and/or being included in any episode of a television show known as The Colbert Report. 12. Any and all tax documents filed, submitted and/or prepared by or on behalf of Plaintiffs for the tax years 2006, 2007, 2008, 2009, and 2010, including but not limited to, any and all tax forms, tax returns, IRS schedules, W-2's, 1099's, and any other supporting documents of any description. 13. Any and all documents filed with the Florida Department of State and/or the Florida Division of Corporations, by or on behalf of Plaintiffs, relating to and/or concerning in any way Caboodle Ranch, Inc, its director(s), board members, or agents. 8

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All documents, of any description, evidencing, relating to and/or concerning Plaintiffs income, including but not limited to bank statements, ledgers, account books, reports, record of donations, record of income, paypal account(s), income from merchandise sales and/or sale of goods.

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All documents, of any description, evidencing, relating to and/or concerning Plaintiffs expenses, including but not limited to bank statements, ledgers, account books, reports.

15.

Printouts and/or digital copies of any and all websites, Facebook pages, YouTube channels, public accounts and/or profiles on third-party websites, Twitter account(s), whether maintained by or on behalf of Plaintiffs, including but not limited to any links, attachments, drafts, substitutions, modifications, additions, subtractions, changes, and alterations made thereto. By means of example, but not limitation, caboodleranch.com, caboodleranch.livejournal.com, caboodle ranch store on zazzle.com, http://www.facebook.com/pages/Caboodle-Ranch-Inc/143028025710287.

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Any and all documents relating to investigation(s) of any kind, whether conducted internally or otherwise, pertaining to the health, welfare, treatment, care, general well-being, and/ or existence of any cat located on property in Madison County, Florida owned, leased, rented, or occupied by Plaintiffs and/or any cat otherwise under the care of Plaintiffs. By means of example, but not limitation, all documents or every description relating to any investigation (whether ongoing or resolved) conducted by or on behalf of the Madison County Animal Control Office, its agents or officers or employees. 9

19.

Produce any and all documents concerning, memorializing, or reflecting any communication between Plaintiffs and Defendant, including but not limited to tape recordings and voice mail.

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Produce a copy of any organizational chart and other documents sufficient to identify the directors, officers, employees and volunteers of Plaintiff Caboodle Ranch, Inc. and the positions each holds or held at any time during the relevant time period.

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Produce all documents of any description evidencing, pertaining to, and/or concerning any cat(s) that have been removed and/or relocated from the care, supervision, and/or control of Plaintiffs and/or from any property owned, leased, rented, and/or otherwise occupied by Plaintiffs. By means of example, but not limitation, any and all documents required by Item 3 of the Affidavit for Order to Show Cause, issued by Judge Wetzel Blair in May 2009. (A copy of the Order to Show Cause is attached hereto as Exhibit A).

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Produce any and all documents evidencing, pertaining to, and/or concerning Item 4 of the Show Cause Order, attached hereto as Exhibit A, requiring [c]omplete medical records of all treated cats during those thirty (30) days including veterinary findings and recommendations, treatment given, etc; not just veterinary receipts.

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Produce any and all documents evidencing, pertaining to, and/or concerning Item 5 of the Show Cause Order, attached hereto as Exhibit A, requiring [r]ecord of any cats that die during the thirty (30) day period, including euthanasia.

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Produce any and all documents evidencing, pertaining to, and/or concerning Item 6 of the Show Cause Order, attached hereto as Exhibit A, requiring [i]f not comply with recommendation, such as euthanasia, he (Grant) must show that the cat was taken to another veterinarian for treatment/hospitalization...

Respectfully Submitted this ___ day of April, 2011. SELLERS, TAYLOR & MORRISON, P.A.

By: ________________________________ Lucas J. Taylor Florida Bar No. 045048 108 West Howard Street Live Oak, FL 32064 Telephone: (386) 208-1080 Facsimile: (386) 208-1090
Attorney for Defendant/Counter-plaintiff Gary Conley

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of the foregoing has been furnished via facsimile and U.S. Mail to Robert Bauer, Esq., 2815 NW 13th Street, Ste. 200E, Gainesville, Florida 32609 at (352) 337-2518 and Pamela Jonasson, 543 Sailfish Drive E., Atlantic Beach, Florida 32233 on this ____ day of February, 2011.

SELLERS, TAYLOR & MORRISON, P.A.

By:

________________________________ LUCAS J. TAYLOR Florida Bar No. 0045048 108 W. Howard St. Live Oak, Florida 32064 Telephone (386) 208-1080 Facsimile (386) 208-1090 Attorney for Gary L. Conley

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