‘subpoena fo» Cit Ma (For Testinony andlor Docu is) (This form replaces CCG NOO6 & COG NOL) _(Rev. 625/09) COG 0106 INTHE CIRCUIT COURT OF COOK COUNTY. ILLINOIS JESSE JACKSON, Cd . No, __16D 0065065, [SANDRA JACKSON, ispondent SUBPOENA IN A CIVIL MATTER (or Testimony andor Documeets) yo ei Cnpats and (SS i ‘Cieege nis 60605 1. You Ane COMMANDED to appear to ie yor tsinony bere the Honerabe inten, noon 7 « 2. YOUARE COMMANDED tosppear and gve yur depaiontetimony efores Notary Pai at; Berger Sehate, LLP, 161 Nit Clark Steet ‘wRoom _ 2400 hiago _Minoison_Febrmey 7 2007 2____200 Bim, and produce the Gocuments requested in the atached Rider, 1D 5. vou are comMANDED te mitthe flowing documeatsin your posession er contal a ‘on oF before (THNS1S FOR RECORDS ONLY. THERE WILL BE NO ORAL INTERROGATORIES): [Zidereription continued on attached pages). ‘YOUR FAILLURE TO RESPOND TO THISSUBPOENA WILL SUBJECT VOU TO PUNISHMENT FOR CONTEMPT OF THIS COURT. Notice w Deponent: . ‘The deponeat is public or private corprstion, partaersip, usec requested are as fll: 0, 0r governmental agency. The matters) which examination is Ci decripion continued on ataced page ( sonpary organization bets duty to digs ove o mor fer, retro munagag agen o oer prensa tei om its eka fd may st forth foreach person designated the malters on which ha person il sty. ML Sop. CX. Ral 206) 1B] 2. tne sepnen’steimony wil be reconded by uo am audiovisual ecrding device operated by representative of1R Coty & Asocates SE janet fcrtn Dei Ope) epoion fay arya tee sal exceed tre ours earcles of the number of parts lavledin the case, except ‘ofthe parties or by order opon showing that goed cause warrants a legtbicr exymlnation I Spp Ci. Rele 2064), ad Pro Se 99500 Named Bay AAs Berger Sets, LLP sve ny Attys Jee sae Sgmere ‘ddregs 16) Nor Clark Set Sue 800 Diatirsey rip: Chicago, Wino ET Ct«~R ero cee caystatez cert eet aot ANT 2 ay ED ser this atpoen by malig» copy os egeird by I Sup. Ct, Rules 11, 12 and 20402, 16 Gey McCarthy by certified mall return recelpt requested (Receipt #217: 969009380068079854 oa ‘paid ee wines § 2500 Tor wines ana leage fees. 7 : D1 trerveatnissubpocondy nding copy, for witness end lenge fees. eee Buy A Schatz rain Name) DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOISder to Sul for Deposition TO: Former Superintendent Garry MeCarthy clo United Service Companies 1550 S. Indiana Avenue Chicago, Mlinois 60605 INSTRUCTIONS (A) General Provision. The request for production of documents in this. Subpddha covers all documents, objects or tangible things, in the possession, control, or otherwise available to the deponent, the deponent’s agents, employees, attorneys, accountants, consultants or other representatives, (B) Supplementation Required, These requests for production are continuing in nature, Deponent shall seasonably supplement, amend or complete any response to the extent that documents, object or tangible things subsequently come into Deponent’s possession or control or become known to Deponent. For example, if Deponent produced statements through December 31, 2016, but generates statements after December 31, 2016, the new statements must be sent as they are recorded. If Deponent has knowledge of documents, objects or tangible things responsive to this request, either now or in the future, Deponent must disclose such information, whether or not the actual documents, objects, or tangible things are in Deponent’s possession. To the extent that responsive documents, objects or tangible things are not in Deponent’s possession, Deponent ‘must identify the location of such responsive.documents, objects or tangible things in the affidavit of compliance as provided for herein. (©) Non-Limiting Language. All requests for production which are stated in the conjunctive are to be read as if stated in the disjunctive and vice-versa (i.,, answer each request as if requiring an and/or response. (D) Copies. Complete and accurate copies will be acceptable compliance with a request for a document, unless the original document is requested. However, original documents mist be available for inspection and maintained for tral. (E) Computer Storage. All material responsive to this request stored on computer or ‘other means of data storage must be produced in printed form as well as on drive, disc or CD. (F) Manner of Production. All documents must be produced in the order in which they are kept in the usual course of business or organized and labeled to correspond with categories in the request. The failure to organize the requested documents constitutes a discovery abuse subject to sanctions. (G) Non-Disclosure. With respect to any documents which deponent withholds or does not disclose that are responsive to this Subpoena, or to the extent that deponent exerts a claim or privilege of non-disclosure, a statement shall be provided setting forth the statute, rule, decision or other basis which is claimed to give rise to such non-disclosure and such statement(s) shall be supported by a description of the nature of the documents, objects or tangible things not produced.(H) Affidavit of Compliance, Please complete, sign and return the Affidavit of ‘Compliance enclosed with your document production. (Authentication by _Certificati Please complete, sign and retum the Authentication by Certification with your document production. This is an option to attempt to avoid a personal appearance by you at a subsequent court appearance to authenticate your records, DEFINITIONS (A) The term “Document” or "Documents" means any kind of written, audio or graphic matter, however produced or reproduced, of any kind or description, whether sent or recived or neither, including originals, copies, and drafts, and both sides thereof, and including, but not limited to, papers, books, letters, photographs, videos, objects, tangible things, correspondence, telegrams, cables, telex messages, memoranda, notes, notations, work papers, transcripts (including trial and deposition transcripts), pleadings, minutes, report, recordings of telephone or other conversations or of interviews or of conferences or of other meetings, affidavits, statements, invoices, bills, receipts, payment confirmations, summaries, opinions, applications, reports, studies, analyses, evaluations, contracts, agreements, journals, statistical records, calendars, appointment books, day timers, day planners, diaries, journals, lists tabulations, sound recordings, video recordings, computer printouts, e- mails, text messages, data processing input and output, microfilms, computer discs or other memory clements, and all other records kept by electronic, photographic, or mechanical means, and things similar to any of the foregoing, however, denominated by you. “Document” or “documents” also shall include any data or electronic media including, but not limited to electronically stored deta on any device or magnetic or optical storage media (such as hard drives, backup tapes, CD-ROMs, JAZ and Zip drives, or floppy drives) as an “active” fle or files (readily readable by one or more computer applications or forensics software); any “deleted” but recoverable electronic files on said media; any electronic file fragments (files that have been deleted and partially overwritten with new data); and slack (data fragments stored randomly from random access memory on a hard drive during the normal operation of a computer [RAM slack] or residual data left on the hard drive ater new data has overwritten some but not all of previously stored data). ‘The term “Document” or “Documents” shall further include any data or electronic media stored in oron any Computer System (as defined herein). (B) The term “Computer System” is defined to include, but is not limited to, network servers, desktops, laptops, notebook computers, tablets, mainframes, and other such computing devices of GARRY McCARTHY, iPhones, Android, or other digital cell phones and pagers. (C) The term “Communication” or “Communications” is defined to include without limitation, and whether oral, visual or written, any and all inquiries, discussions, conferences, statements, utterances, exclamations, conversations, correspondences, letters, notes, telegrams, facsimiles, e-mails, text messages, instant messages, other electronically sent or received messages, memoranda or other forms of conveying information, 22+(D) The terms “relates to,” “relate to,” “;elated to” and “relating to” mean in whole or in part that which regards, constitutes, contains, concems, demonstrates, embodies, evidences, relates, analyzes, identifies, states, refers to, reflects, displays, shows, proves, deals with, pertains to, ori in any way legally, factually or logically connected with the matter set forth or referred to or has a tendency to prove or disprove the matter. ©) __ “And” as well as “or” are to be construed either disjunctively or conjunctively so as to bring within the scope of this Subpoena any matters which otherwise might be construed as outside its scope. (F) The terms “you” and “yours” shall mean GARRY McCARTHY (“McCARTHY"), any agent of MoCARTHY’s, anyone under McCARTHY’s control, any person or entity acting on McCARTHY’s behalf, and any person or entity on whose behalf McCARTHY is acting. (G)___ The term “Entity” includes and is intended to mean any company, limited liability company, firm, non-publicly traded corporation, trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity. (H)__ For purposes of this Subpoena, the term “Interest” includes, but is not limited to, the following types of rights, titles, or legal shares: vested, contingent, beneficial, present, equitable, legal, partial, individual, co-owned or joint. @® Pronouns: The pronouns “she” “her” and “hers” refer to SANDRA JACKSON. (8) “SANDI" refers to SANDRA JACKSON. (K) Whenever appropriate, the singular form of a word should additionally be interpreted in the plural and the plural form of a word should additionally be interpreted in the singular. (L) _ All documents requested in this Subpoena are for Documents prepared, edited, revised, received, sent, or generated during the period from May 1, 2012 to date unless otherwise specified. \CUMENTS TO BE PRODUCED 1. To the extent not already produced in response to or in connection with another request inthis Subpoena, any and all Documents relating to any gifts, including but not limited to, aifts of cash, checks, property (real or personal), Interests, assets or proceeds, that you have given to SANDI and/or any member of her family; as well as any and all gifts that SAND! has given to you. For each such gift, produce any and all Documents reflecting the date of purchase, where the gift was purchased, the purchase price, and all memoranda relating to the gift, including but not limited to all cards, letters, notes, etc,2. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any cash, currency, wire transfers and/or checks received by you from SANDI and/or given, sold, exchanged, traded or bartered by SANDI to you, whether directly or indirectly, including but not limited to the amount received, the date received, the payee (if applicable) and the occasion for the receipt of the cash, currency and/or check. 3. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any cash, currency, wire transfers and/or checks you have given, sold, exchanged, traded or bartered to SANDI or for her benefit, whether directly or indirectly, including but not limited to the amount received, the date given, the payee (if applicable) and the occasion for giving the cash, currency, wire transfer and/or check. 4, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any non-cash item you have given, transferred, sold, exchanged, or bartered to SANDI, whether directly or on her behalf, including, but not limited to the item given, the date given, and/or the occasion forthe giving of the item. 5. _ To the extent not already produced in response to or in connection with another request in this Subpoena, any and ali Documents relating to any non-cash item SANDI has given, transferred, sold, exchanged, or bartered to you, whether directly or on her behalf, including but not limited to the item given, the date given, and/or the occasion for the giving of the item. 6. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to expenses paid, whether or in whole or in part, by SANDI on your behalf, including but not limited to, groceries, liquor, household supplies, rent, mortgage, taxes, maintenance or repairs to your residence, utilities, clothing, grooming, accessories, equipment, Computer Systems, medical, dining out, transportation, entertainment, travel, lodging, salon, bar expenses, spa expenses, etc, including but not limited to cancelled checks, bank statements, charge account records, credit card records, invoices, bills, reimbursement records, receipts and/or invoices. 7. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents evidencing expenses paid, whether in whole or in part, by you, or by other persons or entities at your direction, on behalf of SANDI and/or any member of her family, including but not limited to attorneys’ fees, groceries, household supplies, rent, mortgage, taxes, maintenance and repairs to SANDI's residence, utilities, clothing, grooming, accessories, equipment, Computer Systems, medical, dining out, transportation, entertainment, travel, lodging, salon, bar expenses, restaurant expenses, spa expenses, etc., including, but not limited to, all cancelled checks, bank statements, charge account records, credit card records, reimbursement records and receipts or invoices. 8, To the extent not already produced in response to or in connection with another request in this Subpoena, any and alll Documents relating to any shared expenses with SANDI or expenses that SANDI has split with you in any manner,9. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to all hotel or lodging stays, trips and/or vacations taken with SANDI and/or any of SANDI’s family members or on which you and SANDI and/or any of SANDI’s family members were present, including, but not limited to, all Documents confirming airline and hotel or lodging reservations (including e-mails), a copy of those portions of your passport that would relate to any such travel, bank statements, cancelled checks, credit card statements, reimbursement records, diaries, journals, calendars, travel logs, report, mileage account statements, airline tickets, correspondence (including e-mail and text message) regarding any travel plans, photographs, and receipts of any kind whatsoever evidencing the hotel or lodging stay, trip and/or vacation, destination, dates, duration, hotel, motel or other accommodations, transportation (air, train, cruise, bus, et.) car rental, room service, spa service, honor bar, liquor expense, restaurant expense, dining out, activities, entertainment and any other like information, 10, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents, photographs, films, videos, recordings, computer files, digital photos, digital recordings and the like that you received from SAND, that you sent to SANDI, and/or that reflect you and SANDI together. 11, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents reflecting communication between you and SANDI, including but not limited to, correspondence by or between SANDI and you, e-mails, letters, cards, telephone records, text messages, notes and the like to and/or from SANDI, and any and all Documents reflecting communication with SANDI regarding this litigation, 12. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any and all parties, galas, openings, celebrations, concerts, movies, sporting events, speeches, ceremonies, commemorations, holidays or other like event which you and SANDI attended together and/or where you and SANDI were both in attendance, including, but not limited to, all correspondence (including e-mail and text message) by or between you and SANDI regarding the event, and any invitations, notes, video recordings, audio recordings and photographs relating to such event, 13, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to correspondence by or between you and SANDI and/or any member of SANDI’s family and/or on behalf of SANDI and/or any member of her family, including but not limited to all e-mails, text messages, letters, cards, notes, and the like, including all correspondence regarding this litigation. 14, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any personal or business indebtedness of SANDI, including but not limited to, any actual, pending or proposed: (a) loans made by you (and any Entity you were or presently are associated with), (b) loans made or to be made at your (and any Entity you were or presently are associated with) direction, (c) loans proposed, discussed ‘or made with your (and any Entity you were or presently are associated with) approval to SANDI, and/or (4) loans which you (and any Entity you were or presently are associated with) have or ‘would have guaranteed or otherwise been involved, including but not limited to copies of promissory notes, other notes, applications, memoranda, payment logs or receipts, repayment aoeschedules, security agreements, financial statements submitted in connection with the indebtedness, checks and the like. 15. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any actual, pending or proposed transaction, whether personal or business, between you (and any Entity you were or presently are associated with) and SANDI (and any Entity SANDI was or is presently associated with) or between you and any other person or Entity on SANDI’s behalf, including but not limited to: insurance policies, underwriting, guarantees, investments, leters of intent, offers, memoranda, employment, consulting, procurement, contracts, agreements, applications, deeds, checks, proceeds, compensation, mortgages, notes, appraisals, correspondence, conveyance forms, trust documents, personal financial statements, and all related information, 16. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to all cell phones and land lines maintained by you, for your benefit or use, or in your name reflecting each and every incoming and outgoing call and/or text message relating to SANDI, sent to SANDI, or received by you from ‘SANDI, ftom May 1, 2012 to date. 17. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any and all accounts, whether open or closed, in your name and in the name of SANDI or on which SANDI is or has been an authorized signatory, including but not limited to checking accounts, savings accounts, money market accounts, investment accounts, brokerage accounts, certificates of deposit, etc. With respect to each such account, produce all cancelled checks, check registers, deposit and withdrawal slips, and statements. 18. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all credit card statements for any and all of your credit card ‘accounts on which SANDI is, or ever has been, an authorized signatory or joint account holder, and/or on which she made any charges. 19, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents and/or print-outs relating to any social media activity, including but not limited to activity, whether since deleted or otherwise, on Facebook, ‘WhatsApp, LinkedIn, Twitter, Pinterest, iMessages, KIK messages, Snapchat, or Instagram, of which SANDI and/or her social media contacts or friends and you and/or your social media, contacts or friends are referring to SANDI in any way. 20, _ To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to communication with SANDI that relates to her then-present or future income, finances, assets, employment, career and/or consulting services. 21. _ To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to communication with SANDI thatrelates to her relationship with you and/or that relates to her relationship with and/or marriage to JESSE JACKSON, JR. 22. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any cash, currency, property, asset, or Interest held by you you (and any Entity you were or presently are associated with) on behalf of SANDI forthe period May 1, 2012 to the present. 23. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any cash, currency, property, asset, or interest held by SANDI on your behalf for the period May 1, 2012 to the present. 24, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to the acquisition, by SANDI, of an Interest in any Entity with which you were or currently are associated, 25. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any and all actual, pending or proposed payments, defrayments, cancellations or other consideration made or given by you (and any Entity you were or presently are associated with) to or on behalf of SANDI for any purpose from May 1, 2012 to the present. 26, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any and all actual, pending or proposed payments, defrayments, cancellations or other consideration made or given by SANDI to or on behalf of you (and any Entity you were or preseitly are associated with) for any purpose from May 1, 2012 to the present,iv Mater (For Testimony andlor Decumest) {This form replaces COG NAVE & COG NOM) _{Rev. 625109) COG 0106 Sabpoens i IN THE CIRCUIT COURT OF COOK COUNTY. ILLINOIS ESSE JACKSON, IR. iat No,_16 006806 SANDRA JACKSON, Defendaneapandent SUBPOENA IN A CIVIL MATTER 2 Jes Lave AB Soa Mail ‘Ghisage Minis 60626, 1 You Ane COMMANDED to spear eve sour texinoy Before into, noi, * ™ 7S EZ 2. vouans commanoeD wapperranégineyodepotton tinny before Noy Pubic at SBE Scie LE, 6 Nor Clk Set inRoom __2800 Chicago tMinoison__February 9 27 at, 2:00 P. m.and produce the documents requested in the attached Rider. 2. Youare commaNDED emai faowingdsument in your pseson cr coma a * wn or oer (TINSIS FOR RECORDS ONLY. THERE WILL BENO ORAL INTERROGATORIES): (Zdserition coutioued om attached page. YOUR FAILURE TO RESPOND TO THIS SUBPOENA WILL. SUBJECT YOU TO PUNISHMENT FOR CONTEMPT OF THIS COURT. [Neticet Deponent: {C11 The deponeat is public or private corporation, partners requested are as fllons: associat or goveramental agency, The materts} on which exe CE Desription contiousd on atached pages. (A noaparty organization has a dety to designe one or more officer, directors, or managing agents, or other persons testify omits behalf, and may set forth, for each person designated the matters on which that person will testify. ML Sup. Ct. Rule 206) Ba ne (s tetimony wil be recorded by use of an audionnsual recording device, operated by eee te Col at Cy & Assi, "Rar of Recording Des Oprsor) ition of any party or witnesses shal exceed three hours regardtess ofthe humberof parts Involved in the cas. except od enuse warrants a lengthier exam Wi Sup. CL. Rate 206(4). At. Pro Se 99800 Name: BEV A Sens Berger Sct, LLP fete ‘Atty for, Sos Toko Sgnatere ‘Address: 161 North Clark Stet, Suite 2800, Dattoraey Coytnng Gwiesss Buin epee TBS tet Ui 1 A, 2» | served this subpoews by mailing copy, a required by I Sup. Ct, Rules tt 12nd 2002) to Janes Love ty ceria mal return recept requested (Receipt # 2171969008380060079678 yon __Tersan 17 Ea 1 pid the witness § 23.00 Tor witness and outege tes, 1D tservednissubpoenaby banding copy, on . {psi hens 8. or wines and miege fe Bary A Seta ‘Bignaare ovary Gein Nameh DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY. ILLINOISRider to Subpoena for Deposition TO: Former Office James Love 8418 S, Marshfield Chicago, Illinois 60620 INSTRUCTIONS (A) General Provision, The request for production of documents in this Subpoena covers all documents, objects or tangible things, in the possession, control, or otherwise available to the deponent, the deponent’s agents, employees, attorneys, accountants, consultants or other representatives. (B) Supplementation Required. These requests for production are continuing in nature, Deponent shall seasonably supplement, amend or complete any response to the extent that documents, object or tangible things subsequently come into Deponent’s possession or control or ‘become known to Deponent. For example, if Deponent produced statements through December 31, 2016, but generates statements after December 31, 2016, the new statements must be sent as they are recorded. If Deponent has knowledge of documents, objects or tangible things responsive to this request, either now or in the future, Deponent must disclose such information, whether or not the actual documents, objects, or tangible things are in Deponent's possession. To the extent that responsive documents, objects or tangible things are not in Deponent’s possession, Deponent must identify the location of such responsive documents, objects or tangible things in the affidavit of compliance as provided for herein. (©) Non-Limiting Language, All requests for production which are stated in the conjunctive are to be read as if stated in the disjunctive and vice-versa (ie., answer each request as if requiring an and/or response). () Copies. Complete and accurate copies will be acceptable compliance with a request for a document, unless the original document is requested. However, original documents must be available for inspection and maintained for tral, (E) Computer Storage. All material responsive to this request stored on computer or other means of data storage must be produced in printed form as well as on drive, disc or CD. (F) Manner of Production. All documents must be produced in the order in which they are kept in the usual course of business or organized and labeled to correspond with categories in the request, The failure to organize the requested documents constitutes a discovery abuse subject to sanctions. (G) Non-Disclosure. With respect to any documents which deponent withholds or does not disclose that are responsive to this Subpoena, or to the extent that deponent exerts a claim or privilege of non-disclosure, a statement shall be provided setting forth the statute, rule, decision or other basis which is claimed to give rise to such non-disclosure and such statement(s) shall be supported by a description of the nature of the documents, objects or tangible things not produced,(H) Affidavit of Compliance. Please complete, sign and return the Affidavit of Compliance enclosed with your document production. ® iat ertificati Please complete, sign and return the Authentication by Certification with your document production. This is an option to attempt to avoid a personal appearance by you ata subsequent court appearance to authenticate your records. D INS (A) The term “Document” or "Documents" means any kind of written, audio or graphic matter, however produced or reproduced, of any kind or description, whether sent or received or neither, including original, copies, and drafts, and both sides thereof, and including, but nat limited to, papers, books, letters, photographs, videos, objects, tangible things, correspondence, telegrams, cables, telex messages, memoranda, notes, notations, work papers, transcripts (including trial and deposition transcripts), pleadings, minutes, reports, recordings of telephone or other conversations or of interviews or of conferences or of other meetings, affidavits, statements, invoices, bill, receipts, payment confirmations, summaries, opinions, applications, reports, studies, analyses, evaluations, contracts, agreements, journals, statistical records, calendars, appointment books, day timers, day planners, diaries, journals, lists, tabulations, sound recordings, video recordings, computer printouts, e- tails, text messages, data processing input and output, microfilms, computer dises or other memory elements, and all other records kept by electronic, photographic, or mechanical means, and things similar to any of the foregoing, however, denominated by you, Document” or “documents” also shall include any data or electronic media including, but not ied to electronically stored data on any device or magnetic or optical storage media (such as hard drives, backup tapes, CD-ROMs, JAZ. and Zip drives, or floppy drives) as an “active” file or files (readily readable by one or more computer applications or forensics software); any “deleted” but recoverable electronic files on said media; any electronic file fragments (files that have been deleted and partially overwritten with new data); and slack (data fragments stored randomly from random access memory on a hard drive during the normal operation of a computer (RAM slack] or residual data left on the hard drive after new data has overwritten some but not all of previously stored data). The term “Document” or “Documents” shall further include any data or electronic media stored in ‘or on any Computer System (as defined herein). (B) The term “Computer System” is defined to include, but is not limited to, network servers, desktops, laptops, notebook computers, tablets, mainframes, and other such computing, devices of JAMES LOVE, iPhones, Android, or other digital cell phones and pagers, (©) The term “Communication” or “Communications” is defined to include without limitation, and whether oral, visual or written, any and all inquiries, discussions, conferences, statements, utterances, exclamations, conversations, correspondences, letters, notes, telegrams, facsimiles, e-mails, text messages, instant messages, other electronically sent or received ‘messages, memoranda or other forms of conveying information,(D) The terms “telates to,” “relate to,” “related to” and “relating to” mean in whole or in part that which regards, constitutes, contains, concems, demonstrates, embodies, evidences, relates, analyzes, identifies, states, refers to, reflects, displays, shows, proves, deals with, pertains to, or is in any way legally, factually or logically connected with the matter set forth or referred to or has a tendency to prove or disprove the matter. (©) _ “And” as well as “or” are to be construed either disjunctively or conjunctively so as to bring within the scope of this Subpoena any matters which otherwise might be construed as outside its scope. (©) The terms “you” and “yours” shall mean JAMES LOVE (“LOVE”), any agent of LOVE’s, anyone under LOVE’s control, any person or entity acting on LOVE’s behalf, and any person ot entity on whose behalf LOVE is acting. (G)__ The term “Entity” includes and is intended to mean any company, limited liability company, firm, non-publicly traded corporation, trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity. (H)__ For purposes of this Subpoena, the term “Interest” includes, but is not limited to, the following types of rights, titles, or legal shares: vested, contingent, beneficial, present, equitable, legal, partial, individual, co-owned or joint. Pronouns: The pronouns “she” “her” and “‘hers” refer to SANDRA JACKSON. ( — “SANDI" refers to SANDRA JACKSON, (K) Whenever appropriate, the singular form of a word should additionally be interpreted in the plural and the plural form of a word should additionally be interpreted in the singular, (L) __ All documents requested in this Subpoena are for Documents prepared, edited, revised, received, sent, or generated during the period from January 1, 2012 to date unless otherwise specified. MEN’ DUCED. 1, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any gifts including but not limited to, aifts of cash, checks, property (real or personal), Interests, assets or proceeds, that you have given to SANDI and/or any member of her family; as well as any and all gifts that SANDI has given to ‘you. For each such gift, produce any and all Documents reflecting the date of purchase, where the gift was purchased, the purchase price, and all memoranda relating to the gift, including but not limited to all cards, letters, notes, etc,2, To the extent not already produced in response to or in connection with another request in this Subpoena, any.and all Documents relating to any cash, currency, wire transfers and/or checks received by you from SANDI and/or given, sold, exchanged, traded or bartered by SANDI to you, whether directly or indirectly, including but not limited to the amount received, the date received, the payee (if applicable) and the occasion for the receipt of the cash, currency and/or check. 3. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any cash, currency, wire transfers and/or checks you have given, sold, exchanged, traded or bartered to SANDI ot for her benefit, whether directly or indirectly, including but not limited to the amount received, the date given, the payee (if applicable) and the occasion for giving the cash, currency, wire transfer and/or check. 4, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any non-cash item you have given, ansferred, sold, exchanged, or bartered to SANDI, whether directly or on her behalf, including, but not limited to the item given, the date given, and/or the occasion for the giving of the item. 5. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any non-cash item SANDI has given, ‘transferred, sold, exchanged, or bartered to you, whether directly or on her behalf, including but not limited to the item given, the date given, and/or the occasion for the giving of the item. 6. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to expenses paid, whether or in whole or in part, by SANDI on your behalf, including but not limited to, groceries, liquor, household supplies, rent, mortgage, taxes, maintenance or repairs to your residence, utilities, clothing, grooming, accessories, equipment, Computer Systems, medical, dining out, transportation, ‘entertainment, travel, lodging, salon, bar expenses, spa expenses, etc., including but not limited to cancelled cheeks, bank statements, charge account records, credit card records, invoices, bills, reimbursement records, receipts and/or invoices. 7. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents evidencing expenses paid, whether in whole or in part, by you, or by other persons or entities at your direction, on behalf of SANDI and/or any ‘member of her family, including but not limited to attorneys’ fees, groceries, household supplies, rent, mortgage, axes, maintenance and repairs to SANDI’s residence, utilities, clothing, grooming, accessories, equipment, Computer Systems, medical, dining out, transportation, entertainment, travel, lodging, salon, bar expenses, restaurant expenses, spa expenses, etc., including, but not limited to, all cancelled checks, bank statements, charge account records, credit card records, reimbursement records and receipts or invoices. 8. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any shared expenses with SANDI or expenses that SANDI has split with you in any manner,9. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to all hotel or lodging stays, trips and/or vacations taken with SANDI and/or any of SANDI’s family members or on which you and SANDI and/or any of SANDI's family members were present, including, but not limited to, all Documents ‘confirming airline and hotel or lodging reservations (including e-mails), a copy of those portions ‘of your passport that would relate to any such travel, bank statements, cancelled checks, credit ‘card statements, reimbursement records, diaries, journals, calendars, travel logs, reports, mileage account statements, airline tickets, correspondence (including e-mail and text message) regarding any travel plans, photographs, and receipts of any kind whatsoever evidencing the hotel or lodging stay, trip and/or vacation, destination, dates, duration, hotel, motel or other accommodations, transportation (ar, train, cruise, bus, etc.), car rental, room serviee, spa service, honor bar, liquor expense, restaurant expense, dining out, activities, entertainment and any other like information. 10. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents, photographs, films, videos, recordings, computer files, digital photos, digital recordings and the like that you received from SANDI, that you sent to SANDI, and/or that reflect you and SANDI together. 11, _ To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents reflecting communication between you and ‘SANDI, including but not limited to, correspondence by or between SANDI and you, e-mails, letters, cards, telephone records, text messages, notes and the like to and/or from SANDI, and any arid all Documents reflecting communication with SANDI regarding this litigation. 12. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any and all parties, gales, openings, celebrations, concerts, movies, sporting events, speeches, ceremonies, commemorations, holidays or other like event which you and SANDI attended together and/or where you and SANDI were both in attendance, including, but not limited to, all correspondence (including e-mail and text ‘message) by or between you and SANDI regarding the event, and any invitations, notes, video recordings, audio recordings and photographs relating to such event, 13, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to correspondence by or between you and SANDI and/or any member of SANDI’s family and/or on behalf of SANDI and/or any ily, including but not limited to all e-mails, text messages, letters, cards, notes, and the like, including all correspondence regarding this litigation. 14, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any personal or business indebtedness, uding but not limited to, any actual, pending or proposed: (a) loans made by you (and any Entity you were or presently are associated with), (b) loans made or to be made at your (and any Entity you were or presently are associated with) direction, (c) loans proposed, discussed cor made with your (and any Entity you were or presently are associated with) approval to SANDI, and/or (@) loans which you (and any Entity you were or presently are associated with) have or would have guaranteed or otherwise been involved, including but not limited to copies of promissory notes, other notes, applications, memoranda, payment logs or receipts, repayment 5+schedules, security agreements, financial statements submitted in connection with the indebtedness, checks and the like. 15, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any actual, pending or proposed transaction, whether personal or business, between you (and any Entity you were or presently are associated with) and SANDI (and any Entity SANDI was or is presently associated with) or between you and any other person or Entity on SANDI’s behalf, including but not limited to: insurance policies, underwriting, guarantees, investments, letters of intent, offers, memoranda, employrnent, consulting, procurement, contracts, agreements, applications, deeds, checks, proceeds, compensation, mortgages, notes, appraisals, correspondence, conveyance forms, trust documents, personal financial statements, and all related information. 16. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to all cell phones and land lines ‘maintained by you, for your benefit or use, or in your name reflecting each and every incoming and outgoing call and/or text message relating to SANDI, sent to SANDI, or received by you from SANDI, from January 1, 2012 to date. 17. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any and all accounts, whether open or closed, in your name and in the name of SANDI or on which SANDI is or has been an authorized signatory, including but not limited to checking accounts, savings accounts, money market accounts, investment accounts, brokerage accounts, certificates of deposit, etc. With respect to each such account, produce all cancelled checks, check registers, deposit and withdrawal slips, and statements, 18, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all credit card statements for any and all of your credit card ‘accounts on which SANDI is, or ever has been, an authorized signatory or joint aecount holder, and/or on which she made any charges. 19, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents and/or print-outs relating to any social media activity, including but not limited to activity, whether since deleted or otherwise, on Facebook, ‘WhatsApp, Linkedin, Twitter, Pinterest, iMessages, KIK messages, Snapchat, or Instagram, of which SANDI and/or her social media contacts or friends and you and/or your social media contacts or friends are referring to SANDI in any way. 20, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to communication with SANDI that relates to her then-present or future income, finances, assets, employment, career and/or consulting services. 21, _ To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to communication with SANDI that -6-relates to her relationship with you and/or that relates to her relationship with and/or marriage to JESSE JACKSON, JR. 22, To the extent not alteady produced in response to or in connection with another request in this Subpoena, any and ell Documents relating to any cash, currency, property, asset, or Interest held by you you (and any Entity you were or presently are associated with) on behalf of SANDI for the period January 1, 2012 to the present. 23. To the extent not already produced in response to or in connection with another request inthis Subpoena, any and all Documents relating to any eash, currency, property, asset, or interest held by SANDI on your behalf for the period January 1, 2012 to the present. 24, To the extent not already produced in response {o or in connection with another request in this Subpoena, any and all Documents relating to the acquisition, by SANDI, of an Interest in any Entity with which you were or currently are associated. 25. To the extent not alrcady produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any and all actual, pending or proposed payments, defrayments, cancellations ot other consideration made or given by you (and any Entity you were or presently are associated with) to or on behalf of SANDI for any purpose from January 1, 2012 to the present, 26. To the extent not already produced in response to or in connection with another request inthis Subpoena, any and all Documents relating to any and all actual, pending or proposed payments, defrayments, cancellations or other consideration made or given by SANDI to or on behalf of you (and any Entity you were or presently are associated with) for any purpose from January 1, 2012 to the present.Subpoena ina Civ Mate (For Testimony ander Documents) {This Form replaces COO NOW & CCG NDIA) _ (Rev. 625/09) CCG 0106, INTHE CIRCUIT COURT OF COOK COUNTY. LINOIS. rr [SANDRA JACKSON, DeteadaaVRepondent ‘SUBPOENA IN A CIVIL MATTER (For Tesimony endlor Docume) “To: Ricard Simon of United Services Companies 1550 Sout Tndlana Avene (Chica, Wins 605 1 +. You ake commaNDED te arearo give sour tenon before the Honorable InRoon, noi, merce teste E Ey 2 vouanecommannr.otwappeareed give your dputonetimony before a Notary Public at; BEY Sta, LF, 16 Non Clark Spee {noon _2800 Chiewge iiaotson_ Fobra 8 a, at__200 bn. and produce the documents requesied in the attached Ride. D1 3. YouaRe comMaNneD tomai the ftowing documenta you pstession contra “ oF Before (TiS 1S FOR RUCORDS ONLY, THERE WILL BE NO ORAL INTERROGATORIES): ‘YOUR FAILURE TO RESPOND TO THIS SUBPOENA WILL SUBJECT YOU TO PUNISHMENT FOR CONTEMPT OF THIS COURT. Node eo Deponent 1. The deponeat iss public or private corporation prtarshp, asocaton or governmental agency. The matter() 00 which exami requested areas fllons: contaued on attached page(s) (A sonparty orgaslztion bi to desigate one or mere officer, directors or mancging agents or other persons to tsiy omits Beka, land may se forth for exch person designated, the mater om which that pesen wil esi. I Sup. Ct Rae 2.) 1 (2) 2. The deponen' testimony wl be recorded by ase ofan sede-isual recording deve, operate by ¢pretattive of J Coby & Associates Sra aor 3, Savoy degnon any party or awe sha eee te hours eis fhe eunr pees ee Faure ar ye ape wig fn! ese ran eg egaaen I ep Cale ey ay he Prose 80 Name: Bary A, Schatz / Berger Schatz, LLP Issued by: i a ns eo TE TTT she dur 11 No Cr Se ale Datorsey ern A Reena Denes 17 ONT gs ds tid isa cease ary \ 200 [E_taerved his subpoena by manga copy es required byt, Sop. Ct Ruler ty 12 and 2002), wo Ricard Sinem : serra cat cere eaneeaneed tect SOIBORSPOONRESL yg nay a 1 pald the witness $ 25.00 for witness and mileage fees. 1 Aserved this sutpoens by handing # copy to 0, Tp he wg 8. ierviwosetap es Barry A Schatzto Subpoena for Dé n c. TO: Former Sgt. Richard “Rick” Simon c/o United Service Companies 1550 8. Indiana Avenue Chicago, Iinois 60605 INSTRUCTIONS (A) General Provision, The request for production of documents in this Subpoena covers all documents, objects or tangible things, in the possession, control, or otherwise available to the deponent, the deponent's agents, employees, atfomeys, accountants, consultants or other representatives, B) Supplementation Required, These requests for production are continuing in nature, Deponent shall seasonably supplement, amend or complete any response to the extent that documents, object or tangible things subsequently come into Deponent's possession or control or become known to Deponent. For example, if Deponent produced statements through December 31, 2016, but generates statements after December 31, 2016, the new statements must be sent as they are recorded. If Deponent has knowledge of documents, objects or tangible things responsive to this request, either now or in the future, Deponent must disclose such information, whether or not the actual documents, objects, or tangible things are in Deponent’s possession, To the extent that responsive documents, objects or tangible things are not in Deponent's possession, Deponent ‘must identify the location of such responsive documents, objects or tangible things in the affidavit of compliance as provided for herein, (C) Non-Limiting Language. All requests for production which are stated in the conjunctive are to be read as if stated in the disjunctive and vice-versa (je., answer each request as if requiring an and/or response). ©) Copies. Complete and accurate copies will be acceptable compliance with a request for a document, unless the original document is requested, However, original documents must be available for inspection and maintained for trial, ©) Computer Storage. All material responsive to this request stored on computer or other means of data storage must be produced in printed form as well as on drive, disc or CD. (F) Manner of Production, All documents must be produced in the order in which they are kept in the usual course of business or organized and labeled to correspond with categories in the request. The failure to organize the requested documents constitutes a discovery abuse subject to sanctions. (G) _Non-Disolosure. With respectto any documents which deponent withholds or does not disclose that are responsive to this Subpoena, or to the extent that deponent exerts a claim or privilege of non-disclosure, a statement shall be provided setting forth the statute, rule, decision orother basis which is claimed to give rise to such non-disclosure and such statement(s) shall be supported by a description of the nature of the documents, objects or tangible things not produced, (H) Affidavit of Compliance. Please complete, sign and retum the Affidavit of Compliance enclosed with your document production, () Authentication by Certification. Please complete, sign and retum the Authentication by Certification with your document production, This is an option to attempt to avoid a personal appearance by you at a subsequent court appearance to authenticate your records, DEEINITIONS (A) The term "Document" or "Documents" means any kind of written, audio or graphic matter, however produced or reproduced, of any kind or description, whether sent or received or neither, including originals, copies, and drafts, and both sides thereof, and including, but not limited to, papers, books, letters, photographs, videos, objects, tangible things, correspondence, telegrams, cables, telex messages, memoranda, notes, notations, work papers, transcripts (including tial and deposition transcripts), pleadings, minutes, reports, recordings of telephone or other conversations oF of interviews or of conferences or of other meetings, affidavits, statements, invoices, bills, receipts, payment confirmations, summaries, opinions, applications, reports, studies, analyses, evaluations, contracts, agreements, journals, statistical records, calendars, appointment books, day timers, day planners, diaries, journals, lists, tabulations, sound recordings, video recordings, computer printouts, e- ‘mails, text messages, data processing input and output, microfilms, computer dises or other memory ‘elements, and all other records kept by electronic, photographic, or mechanical means, and things similar to any of the foregoing, however, denominated by you. “Document” of “documents” also shall include any data or electronic media including, but not limited to electronically stored data on any device or magnetic or optical storage media (such as hard drives, backup tapes, CD-ROMs, JAZ and Zip drives, or floppy drives) as an “active” file or files (readily readable by one or more computer applications or forensics software); any “deleted” but recoverable electronic files on said media; any electronic file fragments (files that have been deleted and partially overwritten with new data); and slack (data fragments stored randomly from random access memory on a hard drive during the normal operation of a computer [RAM slack] or residual data left on the hard drive after new data has overwritten some but not all of previously stored data). The term “Document” or “Documents” shall further include any data or electronic media stored in ‘or on any Computer System (as defined herein). (B) The term “Computer System” is defined to include, but is not limited to, network servers, desktops, laptops, notebook computers, tablets, mainframes, and other such computing devices of RICHARD “RICK” SIMON, iPhones, Android, or other digital cell phones and pagers. (©) The term “Communication” or “Communications” is defined to include without limitation, and whether oral, visual or written, any and all inquiries, discussions, conferences, statements, utterances, exclamations, conversations, correspondences, letters, notes, telegrams, +2.facsimiles, e-mails, text messages, instant messages, other electronically sent or received messages, memoranda or other forms of conveying information (D) The terms “Telates to,” “relate to,” “related to” and “relating to” mean in whole or in part that which regards, constitutes, contains, concerns, demonstrates, embodies, evidences, relates, analyzes, identifies, states, refers to, reflects, displays, shows, proves, deals with, pertains to, oris in any way legally, factually or logically connected with the matter set forth or referred to or has a tendency to prove or disprove the matter. (E) “Ang” as well as “or” are to be construed either disjunctively or conjunctively so as to bring within the scope of this Subpoena any matters which otherwise might be construed as, outside its scope. (©) _ The terms “you” and “yours” shall mean RICHARD “RICK” SIMON (“SIMON”), any agent of SIMON's, anyone under SIMON's control (including but not limited to Mr. GARRY SIMON), any person or entity acting on SIMON’s behalf, and any person or entity on whose behalf SIMON is acting. (G)__ The term “Entity” includes and is intended to mean any company, limited liability company, firm, non-publicly traded corporation, trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity. (H) For purposes of this Subpoena, the term “Interest” includes, but is not limited to, the following types of rights, titles, or legal shares: vested, contingent, beneficial, present, ‘equitable, legal, partial, individual, co-owned or joint. (D Pronouns: The pronouns “she” “her” and “hers” refer to SANDRA JACKSON. (2) “SANDY” refers to SANDRA JACKSON. (K)_ Whenever appropriate, the singular form of a word should additionally be interpreted in the plural and the plural form of a word should additionally be interpreted in the singular. (L)__ All documents requested in this Subpoena are for Documents prepared, edited, revised, received, sent, or generated during the period from January 1, 2015 to date unless otherwise specified. pocu BEF! 1, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any gifs, including but not limited to, gifts of cash, checks, property (real or personal), Interests, assets or proceeds, that you have given to SANDI and/or any member of her family. For each such gift, produce any and all Documents arereflecting the date of purchase, where the gift was purchased, the purchase price, and all memoranda relating to the gift, including but not limited to all cards, letters, notes, etc, 2, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any cash, currency, wire transfers and/or checks you have given, sold, exchanged, traded or bartered to SANDI or for her benefit, whether directly or indirectly, including but not limited to the amount received, the date given, the payee (if applicable) and the occasion for giving the cash, currency, wire transfer and/or check. 3. _ To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any non-cash item you have given, transferred, sold, exchanged, or bartered to SANDI, whether directly or on her behalf, including but not limited to the item given, the date given, and/or the occasion for the giving of the item, 4 To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents evidencing expenses paid, whether in whole or in part, by you, or by other persons or entities at your direction, on behalf of SANDI and/or any member of her family, including but not limited to attomeys® fees, groceries, household supplies, rent, mortgage, taxes, maintenance and repairs to SANDI’s residence, utilities, clothing, grooming, accessories, equipment, Computer Systems, medical, dining out, transportation, entertainment, travel, lodging, salon, bar expenses, restaurant expenses, spa expenses, etc., including, but not limited to, all cancelled checks, bank statements, charge account records, credit card records, reimbursement records and receipts or invoices. 5. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents reflecting communication between you and SANDI, including but not limited to, correspondence by or between SANDI and you, e-mails, letters, cards, telephone records, text messages, notes and the like to and/or from SANDI, and any and all Documents reflecting communication with SANDI regarding this litigation, 6. To the extent not already produced in response to or in connection with another * request in this Subpoena, any and all Documents relating to correspondence by or between you and SANDI and/or any member of SANDI’s family and/or on behalf of SANDI and/or any member of her family, including but not limited to all e-mails, text messages, letters, cards, notes, and the like, including all correspondence regarding this litigation, 7. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any personal or business indebtedness of SANDI, including but not limited to, any actual, pending or proposed: (a) loans made by you (and any Entity you were or presently are associated with), (b) loans made or to be made at your (and any Entity you were or presently are associated with) direction, (c) loans proposed, discussed ormade with your (and any Entity you were or presently are associated with) approval to SANDI, and/or (4) loans which you (and any Entity you were or presently are associated with) have or would have guaranteed or otherwise been involved, including but not limited to copies of promissory notes, other notes, applications, memoranda, payment logs or receipts, repayment schedules, security agreements, financial statements submitted in connection with the indebtedness, checks and the like, “4.To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any actual, pending or proposed transaction, whether personal or business, between you (and any Entity you were or presently are associated with) and SANDI (and any Entity SANDI was or is presently associated with) or between you and any other person or Entity on SANDI’s behalf, including but not limited to: insurance policies, underwriting, guarantees, investments, letters of intent, offers, memoranda, employment, consulting, procurement, contracts, agreements, applications, deeds, checks, proceeds, compensation, mortgages, notes, appraisals, correspondence, conveyance forms, trust documents, personal financial statements, and all related information. 9. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to all cell phones and land lines maintained by you, for your benefit or use, or in your name reflecting each and every incoming. and outgoing call and/or text message relating to SANDI, sent to SANDI, or received by you from SANDI, from January 1, 2012 to date. 10, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any and all accounts, whether open or closed, in your name and in the name of SANDI or on which SANDI is or has been an authorized signatory, including but not limited to checking accounts, savings accounts, money market accounts, investment accounts, brokerage accounts, certificates of deposit, etc. With respect to each such account, produce all cancelled checks, check registers, deposit and withdrawal slips, and statements, 11, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all credit card statements for any and all of your credit card accounts on which SANDI is, or ever has been, an authorized signatory or joint account holder, and/or on which she made any charges. 12, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents and/or print-outs relating to any social media activity, including but not limited to activity, whether since deleted or otherwise, on Facebook, ‘WhatsApp, LinkedIn, Twitter, Pinterest, iMessages, KIK messages, Snapchat, or Instagram, of which SANDI and/or her social media contacts or friends and you and/or your social media contacts or friends are referring to SANDI in any way. 13. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to communication with SANDI that relates to her then-present or future income, finances, assets, employment, career and/or consulting services. 14, _ To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to communication with SANDI that relates to her relationship with you and/or that relates to her relationship with and/or marriage to JESSE JACKSON, IR.15, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any cash, currency, property, asset, or Interest held by you you (and any Entity you were or presently are associated with) on behalf of SANDI for the period January 1, 2012 to the present. 16. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to the acquisition, by SANDI, of an Interest in any Entity with which you were or currently are associated. 17. To the extent not already produced in response to or in connection with another request inthis Subpoena, any and all Documents relating to any and all actual, pending or proposed payments, defrayments, cancellations or other consideration made or given by you (and any Entity you were or presently are associated with) to or on behalf of SANDI for any purpose from January 1, 2012 to the present. 18. To the extent not already produced in response to or in connection with another ‘request in this Subpoena, any and all Documents relating to any and all actual, pending or proposed payments, defrayments, cancellations or other consideration made or given by SANDI to or on behalf of you (and any Entity you were or presently are associated with) for any purpose from January 1, 2012 to the present. 19, To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any communication you had with JESSE JACKSON, JR. from January 1, 2015 to the present. 20. To the extent not already produced in response to or in connection with another request in this Subpoena, any and all Documents relating to any communication you had with any sibling of JESSE JACKSON, IR. from January 1, 2015 to the present.