ApplicationCal. Super. - 6th Dist.March 2, 2021SUBP-O3O EMNLADDRESWOP'WD- eric©noveshenfiohtsback com ¢ ., . i L \ ANORNEY 0R PARTY WITHOUT ANORNEY (Name, scare Barnumer. andeddpess): ERIC NOVESHEN choumussamY 436 NE 10TH AVE FORT LAUDERDALE. FL 33301 TELEPHONE No. 504. l I'd.ZIZI FAX N°'{°P’””;9‘ 954.337.7669 ATrORNEY FOR (Name): ER[C NOVESHEN Court for county m which discovery Is to be conducted: SUPERIOR COURT 0F CALIFpRNIA. COUNTY 0F Santa Clara STREETADDRESS: 191 N. FII'St Street MAILINGADDREss: 191 N. First Street CITYANDZIPCODE: San Jose, CA 951 13 WW WE: Downtown Superior Court Court in which action is pending: CWSTATEANDZIP CODE: Fort Lauderdale, FL 33301 Name or Court; 17th Judicial Circuit Court - Broward County, Florida STREETADDRESS: 201 SE 61h Street MAILJNGADDRESS:201 SE 6th Street COUNTRY: U3A ‘ \ \ \ l \ v v x w \ | \ \ CALIFORNLA CASE NUMBER (a any mag ned by noun) 21CV378978 PLAINTIFF/PETJTIONER: ERIC NOVESHEN DEFENDANT/RESPONDENT: MARGARET WELTER, (see attached list) CASE NUMBER (of adion pending outside Calfomia): APPLICATION FOR DISCOVERY SUBPOENA m ACTION PENDING OUTSIDE CALIFORNIA CAGE 201 5-021424 (18) 1. Applicant (name): ERIC NOVESHEN is (check one): Plaintiff E Petitioner E Defendant a Respondent E Other (specific: in the above action. 2. Apg‘alicant requ'ests that this court issue a subpoena for discovery under Code of Civil Procedure sections 2029.100 - 2029.900 to {name and address of deponent orperson in contra! ofpmpen‘y): Records Custodian for Google, Inc. 1600 Amphitheatre Parkway Mountain View, CA 94043 3. Attached is (check one): E the original a tme and correct copy of the document from the court in which the action is pending that requires the person in 2 to (check all that apply): a. E attend and give testimony at a deposition; b - produce and pennit inspection and copying of designated materials, information, ortangible things m the possession custody, or control of the deponent; c, E permit the inspection of premises under the control of the deponent. 3.; 4. Applicant submits with this application a proposed subpoena that includes terms identical to those in the document from the out~of-state court (Code of Civil Procedure section 2029.300(d).) ~ | declare under penalty ofpetjury underthe laws ofthe State of California that the forego' z ’ Date; 2/1 9/2021 Eric Noveshen } (rYPE 0R PRINT NAME) PARW WITHOUTA‘I-rORNEY) Note: This application must be accompanied bythe fee specified in Gove ment Code section 70626. A discovery subpoena must be personally served on 1he deponent in corn ' nce with California law, including Code ofCIviI Procedure section 1985. / Page 1 0H Code of Civil Procedure §§ 2029 100-900Fm“Wm“ “TM““WWUW APPLICATION FOR DISCOVERY SUBPOENA WmmnbmgoyJudnm Counml o! CaMorma susposo [NewJanuary 1.20101 IN ACTION PENDING OUTSIDE CALIFORNIA 216V3789?8 SHORT TITLE: ERIC NOVESHEN vs. -MARGARET WELTER, JOHN DOES 1-30, et. al. (see list below) CASE NUMBER; CAGE 2015-021424 (18) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 ERIC NOVESHEN, Plaintiff, VS. MARGARET WELTER, MARCIA NEWMAN, RANDY TRAN, MARY WELTER, ALISA NOVESHEN, JASON DE CARUFEL EVANS, SHEILAH PACETE, JJN s. NAM, LINDA WATER DAVID SACKS, ELIZABETH VILLEGAS, JOHN DOES #1-30, et. a1., Defendant(s). FULL CAPTION OF CASE IN APPLICATION FOR DISCOVERY SUBPOENA 1N ACTION PENDlNG OUTSIDE 0F CALIFORNIA: IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. : CASE NO. 2015-021424 (18) : CIVIL DIVISION numbers); This page may be used with any JudiciaI Council form or any other paper filed with the courL (Required for verified pleading) The items on this page stated on information and belief are (specifi/item numbers, notline Page Form Appmved by the ADDITIONAL PAGE a a ‘ loo u roam ' ' ' ' M&mflmfiflmfl 1.033371 Attach to Judicial Council Form or Other Court Paper CRO 201. 501 Filing # 12163 1798 E-Filed 02/18/2021 12:29:40 PM IN THE CIRCUIT COURT 0F THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. ERIC NOVESHEN, z Plaintifi, . : CASE N0. 20154121424 (13) vs. : CIVIL DIVISION MARGARET WELTER, MARCIA NEWMAN, RANDY TRAN, MARY WELTER, ALISA NOVESHEN, SHEILAH PACETE, JIN S. NAM, LINDA WATER, DAVID SACKS, ELIZABETH “DOE” VILLEGAS, JOHN DOES #1-30, er. aL, Defendant(s). ALIAS SUBPOENA DUCES TE_CUMOF NONPARTY PRODUCTION 0F DOCUMENTS AND THINGS WITHOUT DEPOSITION Under Fla. R. Civ. P. 1.351 THE STATE 0F FLORIDA: T0: Custodian 0f Records for GOOGLE INC. 1600 Amphitheatre Parkway Mountain View, CA 94043 YOU ARE HEREBY COMMANDED, to produce documents to a person at the offices of Bend Law Group. PC., 555 California Street, Suite #4925, San Francisco, CA 94101 on the 19‘“ dax ofMarch, 2021 at 9:00 a.m., for the production ofdocuments only and no testimony shall be taken in the above-styled cause and to have with you the following: fl 3, You are not required to personally appear to comply with this subpoena, however, ifyou do personally appear, these items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the party who issued this subpoena on or before the scheduled date of production. You may email (to discovery@noveshenfightshackcom), mail, electronically (via facsimile: (954) 337-7669) or hand deliver the COpies t0 the undersigned at any time prior to and thereby eliminate your appearance at that time and place specified above. Please do not file copies with the Court You have the fight to object to the production pursuant to this subpoena at Page 1 of3 COURTWDFJT #2021-0248 - sunmENA GOOGLE “W FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/1 SIZOZI [2:29:37 PM.**" any time before production by giving written notice t0 the party who issued this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: 1) appear as specified; or 2) furnish the records instead of appearing as required above; or 3) object to this subpoena, YOU MAY 13gm CONTEMPTg COURT. You are subpoenaed to appear by the party who issued this subpoena and unless excused from this subpoena by the pany who issued this subpoena or the court, you shall respond to this subpoena as directed. SIGNED AND SEALED this date:w CLERK OF THE CIRCUIT COURT (SEAL) By: . DEPUTY CLERK FOR THE COURT Eric Noveshen, pro se 436 NE 101“ Ave Fort Lauderdale, FL 33301 Telephone: (9S4) 779-2727 Facsimile: (954) 337-7669 senvice@noveshenfiqhtsbackcom If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, t0 the provision of certain assistance. Please contact Diana Sobel, Room 20140, 201 S.E. Sixth Street, Fort Lauderdale, Florida 33301, 954-831-7721 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. Page 2 of3 counLDEF 5202140248 H sunPOENA Goocus PRODUCTION OF DOCUMENTS AND THINGS WITHOUT DEPOSITION Under Fla. R. Civ. P. 1.351 IN LIEU 0F YOUR APPEARANCE, THE DOCUMENTS REQUESTED IN SCHEDUEE “A” MAY BE PROVIDED BY EMAIL, MAIL OR HAND DELIVERY PRIOR T0 THE DATE AND TIME YOUR APPEARANCE IS REQUESTED ON THE ATTACHED SUBPOENA. / SCHEDULE“A" ' " “ A " ‘ 1. Documents that are sufficient to identify the “record information” of the subscriber, the data and/or account owner related to the email “estellehartmanfihmaiLoom” (the “User l”), hosted and/or supported by Google, whether maintained by Google 0r a third party to which Google has access, including, but not limited to, any of the following information: i. The User 1’s name, street address, telephone number(s), recovery telephone number(s), email addresses, and recovery email addresses associated with estel[e.hartman@mnail.com, including but not limited to: ' 1. The date and time CUTC) at which the email account was created; «7 2. The operating system utilized by User 1 from which the email account was created; 3. The Internet Protocol (1P) address from which the email account was created. ii. From January l, 2014 t0 present, all data or metadata showing the User 1’s connections accessing the email address estelle.hartman@2mail.com. including but not limited to: 1. User 1’s connection logs; 2. Each operating system utilized fiom which the email account was accessed by User 1; 3. Each Intemet Protocol (IP) address from which email account was accessed by User l. **>!( None of thc documents, electronically stored information: or tangible Lhinas requested herein is subiect to auv provisions 0fthc Stored Communications Act (“SCA”), 18 U.S.C. 6 2701 e! seq. vaou object to any part of the attached subpoena. please state thc obicction to that item in writingand vou arc required to respond to the remaining items requested herein. . Page 3 of 3 oomrrpmv #2021-0248 a SUBPOENA GOOGLE
