CW Subpoena

BARRY N. JOHNSON, ESQ.
(6255)
RYAN B. BRAITHWAITE, ESQ. (8817)
BENNETT TUELLER JOHNSON & DEERE
3165 East Millrock Drive, Suite 500
Salt Lake City, Utah 84121-4704
Telephone: (801) 438-2000
bjohnson@btjd.com
rbraithwaite@btjd.com
TRAVIS KOCH, ESQ.

(Pro Hac Vice Pending)
OVERSTREET HOMAR & KUKER
508 East Eighteenth Street
Cheyenne, Wyoming 82001
Telephone: (307) 274-4444
travis@kukerlaw.com
CLAYTON E. BAILEY, ESQ.

BENJAMIN L. STEWART, ESQ.
BAILEY BRAUER PLLC
8350 N. Central Expressway, Suite 650
Dallas, Texas 75206
Telephone: (214) 360-7433
cbailey@baileybrauer.com
bstewart@baileybrauer.com
IN THE THIRD JUDICIAL DISTRICT COURT

SALT LAKE COUNTY, STATE OF UTAH
MIKE PETKE, NOTICE OF SUBPOENA FOR

DEPOSITION AND TO PRODUCE
Plaintiff, DOCUMENTS
vs. (CRAIG WAIBEL)
UTAH SOCCER, LLC, d/b/a REAL SALT

LAKE, a Utah limited liability company, Civil No. 190907265
Defendant. Judge Patrick Corum
Notice of Subpoena - Page 1

Pursuant to Rule 45 of the Utah Rules of Civil Procedure, notice is hereby given that
Plaintiff will serve the Subpoena attached hereto as Exhibit A.
DATED this 7TH day of October, 2019.
By: /s/ Ryan B. Braithwaite

Telephone: (801) 438-2000
ADDITIONAL COUNSEL:
TRAVIS KOCH, ESQ.

Wyoming State Bar No. 7-5418
(Pro hac vice pending)
Telephone: (307) 274-4444
travis@kukerlaw.com

Texas State Bar No. 00796151
BAILEY BRAUER PLLC
Campbell Centre I
8350 N. Central Expy., Suite 650
Dallas, Texas 75206
Telephone: (214) 360-7433
ATTORNEYS FOR PLAINTIFF MIKE PETKE

CERTIFICATE OF SERVICE
I hereby certify that on this 7th day of October, 2019, I caused a true and correct copy of
the foregoing NOTICE OF SUBPOENA FOR DEPOSITION AND TO PRODUCE
DOCUMENTS to be served via U.S. Mail and Email upon the following counsel for Defendant:
Cameron M. Hancock
KIRTON McCONKIE
50 East South Temple, Suite 400
Salt Lake City, Utah 84111
chancock@kmclaw.com
/s/ Ryan B. Braithwaite

EXHIBIT A

BARRY N. JOHNSON, ESQ. (6255)
Telephone: (801) 438-2000
bjohnson@btjd.com
TRAVIS KOCH, ESQ.

Telephone: (307) 274-4444
travis@kukerlaw.com

BAILEY BRAUER PLLC
8350 N. Central Expressway, Suite 650
Dallas, Texas 75206
Telephone: (214) 360-7433
bstewart@baileybrauer.com
IN THE THIRD JUDICIAL DISTRICT COURT

SALT LAKE COUNTY, STATE OF UTAH
MIKE PETKE, SUBPOENA FOR DEPOSITION AND

TO PRODUCE DOCUMENTS
Plaintiff,
(CRAIG WAIBEL)
vs.

LAKE, a Utah limited liability company, Civil No. 190907265
Defendant. Judge Patrick Corum
Subpoena - Page 1
THE STATE OF UTAH TO:
Craig Waibel
1327 Quail Meadow Road
Park City, UT 84098
YOU ARE COMMANDED to:
1. Appear and give testimony at a deposition in the above-captioned case on Friday,

October 25, 2019 beginning at 9:30 a.m. and continuing thereafter until
completed at the offices of Bennett Tueller Johnson & Deere, 3165 E. Millrock
Dr., Suite 500, Salt Lake City, UT 84121. The deposition will be recorded by
stenographic means by a certified court reporter; and
2. Completely and accurately copy and produce or permit inspection and copying of all
documents, materials, and electronically-stored information described in Exhibit A in
your possession, custody, or control, and to deliver copies of the same to the offices
of Plaintiff’s counsel, Bennett Tueller Johnson & Deere, 3165 East Millrock Drive,
Suite 500, Salt Lake City, UT 84121, at or before Friday, October 25, 2019 at 9:30
a.m.
A Notice to Persons Served with a Subpoena is attached as Exhibit B. The Notice

explains your rights and obligations. If you are commanded to appear at a trial, hearing, or
deposition, a one-day witness fee must be served with this Subpoena. A one-day witness fee is
$18.50 plus $1.00 for each 4 miles you have to travel over 50 miles (one direction).
You may object to this Subpoena for any of the reasons listed in paragraph 6 of the
Notice by serving a written objection upon the attorney listed at the top of this Subpoena. You
must comply with any part of the Subpoena to which you do not object.
DATED this 7th day of October, 2019.
By: /s/ Ryan B. Braithwaite

Telephone: (801) 438-2000
Subpoena - Page 2
ADDITIONAL COUNSEL:
TRAVIS KOCH, ESQ.

Wyoming State Bar No. 7-5418
Telephone: (307) 274-4444
travis@kukerlaw.com

BAILEY BRAUER PLLC
Campbell Centre I
8350 N. Central Expy., Suite 650
Dallas, Texas 75206
Telephone: (214) 360-7433
ATTORNEYS FOR PLAINTIFF MIKE PETKE
Subpoena - Page 3
EXHIBIT A
DEFINITIONS AND INSTRUCTIONS
Definitions
The term “document” shall mean the originals, any non-identical duplicates (e.g. due to
margin notes, handwritten corrections, modifications or similar alterations) and any copies or
reproductions of any written or recorded matter in your custody, possession or control, or known
by you to exist, including but not limited to, any information that is prepared by hand or is
printed, recorded, reproduced or transcribed by any process. This includes, but is not limited to,
correspondence, memoranda, letters, reports, agreements, communications, telegrams,
telecopies, facsimiles, photocopies, photographs, film, microfilm, microfiche, videotapes, data
processing input and output, electronic mail of any type, texts, computer printouts, summaries
and records of conversations, diaries, tape recordings, maps, surveys, charts, plans, drawings,
minutes of meetings or conferences, lists, reports, summaries of interviews or investigations,
opinions, reports or summaries of negotiations, leases, title opinions, run sheets, drafts, revisions,
contracts, notes, calendars, date books, “day-timers,” checks, expense account records, messages,
receipts, deeds or any other similar type of instrument. The term “document” also includes all
documents by whomever prepared within the care, custody or control as well as documents that
you have a legal right to obtain, documents that you have a right to copy or has access to, and/or
documents that you have placed in the temporary possession, custody, or control of any third
party.
The term “date” shall mean the exact day, month and year, if ascertainable, or if not
ascertainable, the best approximation thereto.
Subpoena - Page 4
The term “communication” shall mean any transmission of information of any type
whatsoever, by any means whatsoever, including but not limited to, telephone conversations,
letters, electronic mail, text messages, telegrams, teletypes, telecopies, facsimile, photocopies,
photographs, written memoranda, electronic mail and/or face-to-face conversation.
“Identify” or “identification” or “describe” means:
a. when used in reference to an individual or person, to state his/her full
name, present or last known residence address, present or last known business address,
and current residence and/or business telephone number.
b. when used in reference to a public or private corporation, governmental
entity, partnership, joint venture, association, or other entity, means to state the nature or
form of the entity; its full name, present or last known business address or operating
address; telephone number; principal line of business; and principals, officers, directors,
or other persons authorized to act for it in connection with the matters referred to in the
particular discovery requested.
c. when used in reference to a writing and recording or photograph, shall
include a statement of the following:
(i) The title, heading, or caption, if any, of such writing and recording,
or photograph;
(ii) The identifying number, letter, or combination thereof, if any, and
the significance or meaning of such numbers, letters, or combination thereof, if
necessary, to understand another writing and recording, or photograph;
Subpoena - Page 5
(iii) The date appearing on such writing and recording, or photograph;
if no date appears thereon, the answer shall so state and shall give the date or
approximate date on which such writing and recording, or photographs, was
prepared;
(iv) The number of pages and the general nature or description of such
writing and recording, or photograph (i.e., whether it is a letter, memorandum,
minutes of a meeting, etc.), with sufficient particularity so as to enable such
writing and recording, or photograph, to be precisely identified;
(v) The name and capacity of the person who signed such writing and
recording, or photograph; if it was not signed, the answer shall so state and shall
give the name of the person or persons who prepared it; and
(vi) The physical location of the writing and recording, or photograph,
and the name of its custodian. In lieu of the foregoing, a copy of the document
may be attached and referenced as an exhibit to your answers.
The word “and” means “and/or” and the word “or” means “and/or.”
The word “any” means “all” and the word “each” means “each and every.”
The term “parties” shall mean “plaintiff” and “defendant” as well as a party’s full or
abbreviated name or pronoun referring to a party means the party and, where applicable, its
owners, directors, members, officers, employees, players, agents, representatives, partners,
corporate parent, subsidiaries or affiliates. This definition is not intended to impose a discovery
obligation on any person who is not a party to the litigation or the recipient of a subpoena.
Subpoena - Page 6
The term “RSL” shall mean Utah Soccer, LLC d/b/a Real Salt Lake, and any agents,
representatives, directors, members, owners, officers, employees, agents, representatives,
affiliates, subsidiaries, related entities, predecessors, successors, attorneys and/or any other
individuals or entities acting for or on behalf of Utah Soccer, LLC d/b/a Real Salt Lake.
The term “Petke” shall mean Mike Petke, the Plaintiff named in this case.
The terms “you,” “your” or “Waibel” shall mean Craig Waibel, and any agents,
representatives, employees, spouses, heirs, attorneys and/or any other individuals or entities
acting for or on behalf of Craig Waibel.
The terms “statement” or “statements” shall mean a written statement signed or otherwise
adopted or approved in writing by the person making it or a stenographic, mechanical, electrical,
or other type of recording of a person’s oral statement or any substantially verbatim transcription
of such a recording.
Instructions.
1. To the extent any document request below (“Request”) is objected to, please set
forth the complete reasons for the objections. If you claim a privilege as grounds for not
answering any Request in whole or in part, describe the factual basis for your claim of privilege,
including relevant dates and persons involved, in sufficient detail as to permit the court to
adjudicate the validity of the claim. If you object in part to any Request, specifically identify the
portion of the Request to which you are objecting and answer the remainder completely. Any
request for extension of time must be in writing.
2. In the requests, the singular includes the plural and the plural includes the
singular, the past tense includes the present tense and the present tense includes the past tense.
Subpoena - Page 7
3. If the information requested is stored only on software or by other electronic
means, you should either produce the raw data, along with all codes or programs for translating it
into usable form, or the information in a finished, usable form which would include all necessary
glossaries, keys, indices, and metadata for interpretation of the material.
4. All documents and/or other data compilations which might impact on the subject
matter of this litigation shall be preserved and any ongoing process of document destruction
involving such documents should cease.
5. If any document which contained relevant information has been destroyed or is no
longer in existence state: (i) the identity of the person(s) preparing it and the sender thereof;
(ii) the identity of the addressee, if any; (iii) the date of preparation; and (iv) the date and manner
of distribution, if any.
6. Unless otherwise specified, the applicable time period over which inquiry is made
in the requests is January 1, 2019 to the present.
7. In the requests, the definition of words or expressions shall be their generally
understood meaning. To assist you in preparing your answers, please refer to the definitions
provided when responding to each of the requests.
DOCUMENTS TO BE PRODUCED
1. A full, complete, and legible copy of any and all documents and communications
between you and RSL regarding Mike Petke.
Subpoena - Page 8
between you and RSL regarding or in any way related to the July 24, 2019 Leagues Cup match
between RSL and Tigres UANL.
between you and Major League Soccer regarding or in any way related to Mike Petke.
between you and Major League Soccer regarding or in any way related to RSL, including but not
limited to the July 24, 2019 Leagues Cup match between RSL and Tigres UANL.
between you and Dell Loy Hansen regarding or in any way relating to Mike Petke.
between you and Dell Loy Hansen regarding or in any way relating to RSL
in your possession, custody or control regarding or in any way relating to Mike Petke.
in your possession, custody or control regarding or in any way relating to the July 24, 2019
Leagues Cup match between RSL and Tigres UANL.
9. A full, complete and legible copy of any and all documents and communications
between you and RSL regarding or in any way relating to any press releases mentioning or
otherwise referring to Mike Petke.
Subpoena - Page 9
between you and RSL regarding or in any way relating to RSL’s termination of any contract or
agreement with Mike Petke.
between you and Dell Loy Hansen regarding or in any way relating to RSL’s termination of any
contract or agreement with Mike Petke
between you and RSL regarding or in any way relating to Mike Petke’s lawsuit naming RSL as a
defendant.
between you and Dell Loy Hansen regarding or in any way relating to Mike Petke’s lawsuit
naming RSL as a defendant.
14. A full, complete and legible copy of any and all agreements between you and
RSL regarding or in any way relating to your departure as RSL’s general manager.
15. A full, complete and legible copy of any and all agreements between you and Dell
Loy Hansen regarding or in any way relating to your departure as RSL’s general manager
between you and RSL regarding or in any way relating to your departure as RSL’s general
manager.
between you and Dell Loy Hansen regarding or in any way relating to your departure as RSL’s
general manager.
Subpoena - Page 10
between you and any other individuals or entities regarding or in any way relating to your
departure as RSL’s general manager.
19. A full and complete copy of any audiotapes of communications with RSL
regarding or in any way relating to Mike Petke.
20. A full and complete copy of any audiotapes of communications with Mike Petke.
21. A full and complete copy of any audiotapes of communications with Dell Loy
Hansen regarding or in any way relating to Mike Petke.
Subpoena - Page 11
EXHIBIT B
NOTICE OF PERSONS SERVED WITH A SUBPOENA
(1) Rights and responsibilities in general. A subpoena is a court order whether it is issued by
the court clerk or by an attorney as an officer of the court. You must comply or file an objection,
or you may face penalties for contempt of court. If you are commanded to produce documents or
tangible things, the subpoena must be served on you at least 14 days before the date designated
for compliance. If you are commanded to appear at a trial, hearing, deposition, or other place, a
one-day witness fee must be served with this subpoena. A one-day witness fee is $18.50 plus
$1.00 for each 4 miles you have to travel over 50 miles (one direction). When the subpoena is
issued on behalf of the United States or Utah, fees and mileage need not be tendered. The
witness fee for each subsequent day is $49.00 plus $1.00 for each 4 miles you have to travel over
50 miles (one direction).
(2) Subpoena to copy and mail documents. If the subpoena commands you to copy documents
and mail the copies to the attorney or party issuing the subpoena, you must organize the copies as
you keep them in the ordinary course of business or organize and label them to correspond with
the categories in the subpoena. The party issuing the subpoena must pay the reasonable cost of
copying the documents. You must mail with the copies a Declaration of Compliance with
Subpoena stating in substance:
(A) that you have knowledge of the facts contained in the declaration;
(B) that the documents produced are a full and complete response to the subpoena;
(C) that originals or true copies of the original documents have been produced; and
(D) the reasonable cost of copying the documents.
A Declaration of Compliance with Subpoena form is part of this Notice; you may need to modify
it to fit your circumstances.
(3) Subpoena to appear. If the subpoena commands you to appear at a trial, hearing, deposition,
or for inspection of premises, you must appear at the date, time, and place designated in the
subpoena. The trial or hearing will be at the courthouse in which the case is pending. For a
deposition or inspection of premises, you can be commanded to appear in only the following
counties:
(A) If you are a resident of Utah, the subpoena may command you to appear or to
produce documents, electronic records or tangible things or to permit inspection of
premises in the county:
in which you reside;
in which you are employed;
in which you transact business in person; or
in which the court orders.
Subpoena - Page 12
(B) If you are not a resident of Utah, the subpoena may command you to appear or to
produce documents, electronic records or tangible things or to permit inspection of
premises in the county:
in which you are served with the subpoena; or
in which the court orders.
(4) Subpoena to permit inspection of premises. If the subpoena commands you to appear and
to permit the inspection of premises, you must appear at the date, time, and place designated in
the subpoena and do what is necessary to permit the premises to be inspected.
(5) Subpoena to produce documents or tangible things. If the subpoena commands you to
produce documents or tangible things, you must produce the documents or tangible things as you
keep them in the ordinary course of business or organize and label them to correspond with the
categories in the subpoena. The subpoena may require you to produce the documents at the trial,
hearing, or deposition or to mail them to the issuing party or attorney. The party issuing the
subpoena must pay the reasonable cost of copying and producing the documents or tangible
things. You must produce with the documents or tangible things a Declaration of Compliance
with Subpoena stating in substance:
(A) that you have knowledge of the facts contained in the declaration;
(B) that the documents produced are a full and complete response to the subpoena;
(C) that originals or true copies of the original documents have been produced; and
(D) the reasonable cost of copying the documents.
A Declaration of Compliance with Subpoena form is part of this Notice; you may need to modify
it to fit your circumstances.
(6) Objection to a subpoena. You must comply with those parts of the subpoena to which you
do not object. You may object to all or part of the subpoena if it:
(A) fails to allow you a reasonable time for compliance (If you are commanded to
produce documents or tangible things, the subpoena must be served on you at least 14
days before the date designated for compliance.);
(B) requires you, as a resident of Utah, to appear at a deposition or to produce documents,
electronic records or tangible things or to permit inspection of premises in a county in
which you do not reside, are not employed, or do not transact business in person, unless
the judge orders otherwise;
(C) requires you, as a non-resident of Utah, to appear at a deposition or to produce
documents, electronic records or tangible things or to permit inspection of premises in a
county other than the county in which you were served, unless the judge orders
otherwise;
(D) requires you to disclose privileged or other protected matter and no exception or
waiver applies;
Subpoena - Page 13
(E) requires you to disclose a trade secret or other confidential research, development, or
commercial information;
(F) subjects you to an undue burden; or
(G) requires you to disclose an unretained expert's opinion or information not describing
specific events or occurrences in dispute and resulting from the expert's study that was
not made at the request of a party.
(7) How to object. To object to the subpoena, serve the Objection to Subpoena on the party or
attorney issuing the subpoena. The name and address of that person should appear in the upper
left corner of the subpoena. You must do this before the date for compliance. An Objection to
Subpoena form is part of this Notice; you may need to modify it to fit your circumstances. Once
you have filed the objection, do not comply with the subpoena unless ordered to do so by the
court.
(8) Motion to compel. After you make a timely written objection, the party or attorney issuing
the subpoena might serve you with a motion for an order to compel you to comply and notice of
a court hearing. That motion will be reviewed by a judge. You have the right to file a response to
the motion, to attend the hearing, and to be heard. You have the right to be represented by a
lawyer. If the judge grants the motion, you may ask the judge to impose conditions to protect
you.
(9) Organizations. An organization that is not a party to the suit and is subpoenaed to appear at
a deposition must designate one or more persons to testify on its behalf. The organization may
set forth the matters on which each person will testify. URCP 30(b)(6).
Subpoena - Page 14
My Name:
Address:
Phone:
Email:
IN THE THIRD JUDICIAL DISTRICT COURT OF SALT LAKE COUNTY
STATE OF UTAH
Court Address: 450 S. State Street, Salt Lake City, UT 84114
MIKE PETKE, OBJECTION TO SUBPOENA
Plaintiff,
vs.
UTAH SOCCER, LLC, d/b/a REAL SALT Civil No.

LAKE, a Utah limited liability company,
Judge
Defendant.
Instructions: URCP 45 limits the grounds for an objection. For each of the grounds other than
(2) or (3) please provide a full explanation. Attach additional sheets as necessary.
I have been served with a subpoena in this case, and I object because the subpoena:
(1) Fails to allow me a reasonable time in which to comply.
(2) Requires me, a resident of Utah, to:
appear at a deposition;
produce documents, electronic records or tangible things; or
permit inspection of premises
in a county in which I do not reside, am not employed, and do not transact business in
person.
Subpoena - Page 15
(3) Requires me, a non-resident of Utah, to:
appear at a deposition;
produce documents, electronic records or tangible things; or
permit inspection of premises
in a county other than the county in which I was served.
(4) Requires me to disclose privileged or other protected matter and no exception or

waiver applies.
Instructions for (4): If you object to the subpoena for these grounds, you must describe the
nature of the document or thing with sufficient specificity to enable the party or attorney to
contest your objection.
(5) Requires me to disclose a trade secret or other confidential research, development,

or commercial information.
Instructions for (5): If you object to the subpoena for these grounds, you must describe the
nature of the document or thing with sufficient specificity to enable the party or attorney to
contest your objection.
(6) Subjects me to an undue burden.
(7) Requires me to disclose an unretained expert's opinion or information not

describing specific events or occurrences in dispute and resulting from the expert's study that
was not made at the request of a party.
(8) Other.
Subpoena - Page 16
I declare under criminal penalty of Utah Code Section 78B-5-705 that this Objection to
Subpoena is true and correct.
Date Sign here ►

Typed or printed name
Custodian of the records
Attorney for the custodian of the records
Certificate of Service
I certify that I served a copy of this Objection to Subpoena on the following people.
Person’s Served at this Served on
Name Method of Service Address this Date
Mail
Hand Delivery
Fax (Person agreed to service by fax.)
Email (Person agreed to service by
email.)
Left at business (With person in charge
or in receptacle for deliveries.)
(Other Party Left at home (With person of suitable
or Attorney) age and discretion residing there.)
Mail
(Clerk of Hand Delivery
Court) Electronic File
Mail
Hand Delivery
email.)
Left at home (With person of suitable
age and discretion residing there.)
Mail
Hand Delivery
email.)
Subpoena - Page 17
I certify that I served a copy of this Objection to Subpoena on the following people.
Date Sign here ►

Subpoena - Page 18
My Name:
Address:
Phone:
Email:
IN THE THIRD JUDICIAL DISTRICT COURT OF SALT LAKE COUNTY
STATE OF UTAH
Court Address: 450 S. State Street, Salt Lake City, UT 84114
MIKE PETKE, DECLARATION OF COMPLIANCE

WITH SUBPOENA
Plaintiff,
vs.

LAKE, a Utah limited liability company, Civil No.
Defendant. Judge
(1) I have knowledge of the facts contained in this declaration.
(2) The documents or tangible things copied or produced are a full and complete response to
the subpoena.
(3) The documents or tangible things are
the originals.
copies that are true copies of the originals.
(4) The reasonable cost of copying or producing the documents or tangible things is
$___________________.
I declare under criminal penalty of Utah Code Section 78B-5-705 that this Declaration of
Compliance with Subpoena is true and correct.
Date Sign here ►
Subpoena - Page 19
Custodian of the records
Attorney for the custodian of the records
I certify that I served a copy of this Declaration of Compliance with Subpoena on the following
people.
Mail
Hand Delivery
email.)
(Other Party Left at home (With person of suitable
or Attorney) age and discretion residing there.)
Mail
(Clerk of Hand Delivery
Court) Electronic File
Mail
Hand Delivery
email.)
Mail
Hand Delivery
email.)
Date Sign here ►
Subpoena - Page 20

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BARRY N. JOHNSON, ESQ.

TRAVIS KOCH, ESQ.

CLAYTON E. BAILEY, ESQ.

IN THE THIRD JUDICIAL DISTRICT COURT

MIKE PETKE, NOTICE OF SUBPOENA FOR

vs. (CRAIG WAIBEL)

UTAH SOCCER, LLC, d/b/a REAL SALT

Defendant. Judge Patrick Corum

Notice of Subpoena - Page 1

Plaintiff will serve the Subpoena attached hereto as Exhibit A.

DATED this 7TH day of October, 2019.

BENNETT TUELLER JOHNSON & DEERE

By: /s/ Ryan B. Braithwaite

TRAVIS KOCH, ESQ.

CLAYTON E. BAILEY, ESQ.

ATTORNEYS FOR PLAINTIFF MIKE PETKE

Notice of Subpoena - Page 2

the foregoing NOTICE OF SUBPOENA FOR DEPOSITION AND TO PRODUCE

/s/ Ryan B. Braithwaite

Notice of Subpoena - Page 3

Notice of Subpoena - Page 4

TRAVIS KOCH, ESQ.

CLAYTON E. BAILEY, ESQ.

IN THE THIRD JUDICIAL DISTRICT COURT

MIKE PETKE, SUBPOENA FOR DEPOSITION AND

UTAH SOCCER, LLC, d/b/a REAL SALT

Defendant. Judge Patrick Corum

YOU ARE COMMANDED to:

1. Appear and give testimony at a deposition in the above-captioned case on Friday,

A Notice to Persons Served with a Subpoena is attached as Exhibit B. The Notice

DATED this 7th day of October, 2019.

BENNETT TUELLER JOHNSON & DEERE

By: /s/ Ryan B. Braithwaite

TRAVIS KOCH, ESQ.

CLAYTON E. BAILEY, ESQ.

ATTORNEYS FOR PLAINTIFF MIKE PETKE

DEFINITIONS AND INSTRUCTIONS

correspondence, memoranda, letters, reports, agreements, communications, telegrams,

telecopies, facsimiles, photocopies, photographs, film, microfilm, microfiche, videotapes, data

minutes of meetings or conferences, lists, reports, summaries of interviews or investigations,

ascertainable, the best approximation thereto.

photographs, written memoranda, electronic mail and/or face-to-face conversation.

“Identify” or “identification” or “describe” means:

a. when used in reference to an individual or person, to state his/her full

and current residence and/or business telephone number.

b. when used in reference to a public or private corporation, governmental

particular discovery requested.

c. when used in reference to a writing and recording or photograph, shall

include a statement of the following:

(ii) The identifying number, letter, or combination thereof, if any, and

the significance or meaning of such numbers, letters, or combination thereof, if

necessary, to understand another writing and recording, or photograph;

approximate date on which such writing and recording, or photographs, was

writing and recording, or photograph (i.e., whether it is a letter, memorandum,

minutes of a meeting, etc.), with sufficient particularity so as to enable such

writing and recording, or photograph, to be precisely identified;

(vi) The physical location of the writing and recording, or photograph,

may be attached and referenced as an exhibit to your answers.

owners, directors, members, officers, employees, players, agents, representatives, partners,

representatives, directors, members, owners, officers, employees, agents, representatives,

acting for or on behalf of Craig Waibel.

adopted or approved in writing by the person making it or a stenographic, mechanical, electrical,

request for extension of time must be in writing.