Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832
0G278 - T8
EXHIBIT 1
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832
0G278 - Ts
COURT GF COMMON PLEAS, FRANKLIN COUNTY, ONTO
ahpoena - Civil
Dean Dens at
mt a Nf. OO O82
Case
WS E>
State Teac chars Rei! ent Board see
REE ve
8
ings.
YOU aR f HERESY COMMANDER PO SURPYENA THE FOLLOWING NAMEN PERSON, wi
Segal Ce eee Sng, 401 Nonih ¥
6
> 800
i
=
& OC iL 28
Ra
Pe. County @ LU
Oe cs af A Str By 9 1809 Cala is §5, oF oS Sa18 iy dx ay of
ay a
42 ao clo eS y COUR w
NE AND sy NYATATR wo
DK O YIGN
GS TANG 4 NTAAy Rik
eeME
23 ay
cM Ag Qe SEN KOK
a
aM AR:
OK on
ORG
ae
gh Seay G08845
w so set Moxy nosey, & af Cassia Meas
A
Yolage Sa! Ss
SRERIEE FEES RETURN OF SERVICE
i shows
3302
ny
see s oe
abe
x y Chak,
ooSe
NEYYE: Read ali information on fhe ECG 2 WARE ¢ this sulypocna
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832
0G278 - Ts
CIVIL RULE 45 (C) PROTECTION OF PERSONS SUBJECT TO SUBPOENAS.
Aparly or an attorney responsible for the issuance and service of a subpoena shall take reasonable steps to avoid imposing undue
burden or expense on a person subject to that subpoena.
(a) Aperson commanded to produce under divisions (a)(1)(b)(ii), (iii), (iv), or (v) of this rule need not appear in person at the place of
production or inspection unless commanded to attend and give testimony at a deposition, hearing, or trial.
(b) Subject to division (d)(2) of this rule, a person commanded to produce under divisions (a)(1)(b)(i), (ili), (iv), oF (v) of this rule may,
within fourteen days after service of the subpoena or before the time specified for compliance if such time is less than fourteen
days after service, serve upon the party or attorney designated in the subpoena written objections to production. If objection is
made, the party serving the subpoena shall not be entitled to production except pursuant to an order of the court by which the
subpoena was issued. If objection has been made, the party serving the subpoena, upon notice to the person commanded to
produce, may move at any time for an orderto compel the production. An order to compel production shall protect any person who
is not a party or an officer of a party from significant expense resulting from the production commanded.
On timely motion, the court from which the subpoena was issued shall quash or modify the subpoena, or order appearance or pro-
duction only under specified conditions, if the subpoena does any of the following:
(a) Fails to allow reasonable time to comply;
(b) Requires disclosure of privileged or otherwise protected matter and no exception or waiver applies;
(c) Requires disclosure of a fact known or opinion held by an expert not retained or specially employed by any party in anticipation of
litigation or preparation for trial as described by Civ. R. 26(B)(5), if the fact or opinion does not describe specific events or occur-
rences in dispute and results from study by that expert that was not made at the request of any party;
(d) Subjects a person to undue burden.
Before filing a motion pursuant to division (c)(3)(d) of this rule, a person resisting discovery under this rule shall attempt to resolve any
claim of undue burden through discussions with the issuing attorney. A motion filed pursuant to division (c)(3)(d) of this rule shall be
supported by an affidavit of the subpoenaed person or a certificate of that person's attorney of the efforts made to resolve any claim
of undue burden.
If a motion is made under division (c)(3)(c) or (c)(3)(d) of this rule, the court shall quash or modify the subpoena unless the party in
whose behalf the subpoena is issued shows a substantia! need for the testimony or material that cannot be otherwise met without
undue hardship and assures that the person to whom the subpoena is addressed will be reasonably compensated
CIVIL RULE 45 (D) DUTIES IN RESPONDING TO SUBPOENA.
A person responding to a subpoena to produce documents shall, at the person's option, produce them as they are kept in the usual
course of business or organized and labeled to correspond with the categories in the subpoena. A person producing documents or
electronically stored information pursuant to a subpoena for them shall permit their inspection and copying by all parties present at
the time and place set in the subpoena for inspection and copying.
If a request does not specify the form or forms for producing electronically stored information, a person responding to a subpoe-
na may produce the information in a form or forms in which the information is ordinarily maintained if that form is reasonably useable,
or in any form that is reasonably useable. Unless ordered by the court or agreed to by the person subpoenaed, a person responding
to a subpoena need not produce the same electronically stored information in more than one form.
Aperson need not provide discovery of electronically stored information when the production imposes undue burden or expense. On
motion to compel discovery or for a protective order, the person from whom electronically stored information is sought must show
that the information is not reasonably accessible because of undue burden or expense. !f a showing of undue burden or expense
is made, the court may nonetheless order production of electronically stored information if the requesting party shows good cause.
The court shall consider the factors in civ. R. 26(b)(4) when determining if good cause exists. In ordering production of electronically
stored information, the court may specify the format, extent, timing, allocation of expenses and other conditions for the discovery of
the electronically stored information.
When information subject to a subpoena is withheld on a claim that it is privileged or subject to protection as trial preparation mate-
tials, the claim shall be made expressly and shall be supported by a description of the nature of the documents, communications, or
things not produced that is sufficient to enable the demanding party to contest the claim.
if information is produced in response to a subpoena that is subject to a claim of privilege or of protection as trial-preparation materi-
al, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified,
a receiving party must promptly return, sequester, or destroy the specified information and any copies within the party's possession,
custody or control. A party may not use or disclose the information until the claim is resolved. A receiving party may promptly present
the information to the court under seal for a determination of the claim of privilege or of protection as trial-preparation material. If the
receiving party disclosed the information before being notified, it must take reasonable steps to retrieve it The person who produced
the information must preserve the information until the claim is resolved.
OC-DR-82 (Rev. 9-2018)
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832
0G278 - T8
EXHIBIT 3
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832
0G278 = of B@reo srarEes
Ss POSTAL SERVICE
February 23, 2023
Dear Leigh Joyce:
The following is in response to your request for proof of delivery on your item with the tracking number:
9171 9690 0935 0255 2941 14.
Status: Delivered, Front Desk/Reception/Mail Room
Status Date / Time: February 23, 2023, 9:57 am
Location: CHICAGO, IL 60606
Postal Product: First-Class Mail®
Extra Services: Certified Mail™
Return Receipt Electronic
Signature of Recipient:
See Conse ting
Seep! Corals
Address of Recipient: 4 C15
| Pelkey
SO
Note: Scanned image may reflect a different destination address due to Intended Recipient's delivery instructions on file.
Thank you for selecting the United States Postal Service® for your mailing needs. If you require additional
assistance, please contact your local Post Office™ or a Postal representative at 1-800-222-1811.
Sincerely,
United States Postal Service®
475 L'Enfant Plaza SW
Washington, D.C. 20260-0004
v= Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832
0G278 - T87 9171 9690 0935 0255 2941 14
Higih Street, Suite 1 0
Taft/
bi ol 43215
221.2838 | Fax 2007
Leigh B. Joyce
614.334.6164
ljoyce@taftiaw.com
February 21, 2023
BY CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Segal Consulting
101 North Wacker Drive
Suite 500
Chicago, IL 60606-1724
Re: Dean Dennis, et al. v. State Teachers Retirement Board
Franklin County, Ohio, Court of Common Pleas
Case No. 21 CV 006832
To Whom It May Concern:
Please find enclosed with this correspondence a Civil Action Cover Sheet in the
Circuit Court of Cook County, Illinois, IL Sup. Ct, Rule 204 Subpoena for a Foreign Action
Cover Sheet, and Circuit Court of Cook County, Illinois, Subpoena in a Civil Matter with
corresponding attachments.
Please let me know if you have any questions concerning this subpoena. Thank
you for your attention to this matter.
D
Si cerely,
G enon
o
Leigh B. Joyce
LBJ
Enclosures
764625811
Tall Stettinus § Hollisios LLP 7 altas.com 7 The Moder ow Em
Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832 0G278 - T8 EXHIBIT 1 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832 0G278 - Ts COURT GF COMMON PLEAS, FRANKLIN COUNTY, ONTO ahpoena - Civil Dean Dens at mt a Nf. OO O82 Case WS E> State Teac chars Rei! ent Board see REE ve 8 ings. YOU aR f HERESY COMMANDER PO SURPYENA THE FOLLOWING NAMEN PERSON, wi Segal Ce eee Sng, 401 Nonih ¥ 6 > 800 i = & OC iL 28 Ra Pe. County @ LU Oe cs af A Str By 9 1809 Cala is §5, oF oS Sa18 iy dx ay of ay a 42 ao clo eS y COUR w NE AND sy NYATATR wo DK O YIGN GS TANG 4 NTAAy Rik eeME 23 ay cM Ag Qe SEN KOK a aM AR: OK on ORG ae gh Seay G08845 w so set Moxy nosey, & af Cassia Meas A Yolage Sa! Ss SRERIEE FEES RETURN OF SERVICE i shows 3302 ny see s oe abe x y Chak, ooSe NEYYE: Read ali information on fhe ECG 2 WARE ¢ this sulypocna Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832 0G278 - Ts CIVIL RULE 45 (C) PROTECTION OF PERSONS SUBJECT TO SUBPOENAS. Aparly or an attorney responsible for the issuance and service of a subpoena shall take reasonable steps to avoid imposing undue burden or expense on a person subject to that subpoena. (a) Aperson commanded to produce under divisions (a)(1)(b)(ii), (iii), (iv), or (v) of this rule need not appear in person at the place of production or inspection unless commanded to attend and give testimony at a deposition, hearing, or trial. (b) Subject to division (d)(2) of this rule, a person commanded to produce under divisions (a)(1)(b)(i), (ili), (iv), oF (v) of this rule may, within fourteen days after service of the subpoena or before the time specified for compliance if such time is less than fourteen days after service, serve upon the party or attorney designated in the subpoena written objections to production. If objection is made, the party serving the subpoena shall not be entitled to production except pursuant to an order of the court by which the subpoena was issued. If objection has been made, the party serving the subpoena, upon notice to the person commanded to produce, may move at any time for an orderto compel the production. An order to compel production shall protect any person who is not a party or an officer of a party from significant expense resulting from the production commanded. On timely motion, the court from which the subpoena was issued shall quash or modify the subpoena, or order appearance or pro- duction only under specified conditions, if the subpoena does any of the following: (a) Fails to allow reasonable time to comply; (b) Requires disclosure of privileged or otherwise protected matter and no exception or waiver applies; (c) Requires disclosure of a fact known or opinion held by an expert not retained or specially employed by any party in anticipation of litigation or preparation for trial as described by Civ. R. 26(B)(5), if the fact or opinion does not describe specific events or occur- rences in dispute and results from study by that expert that was not made at the request of any party; (d) Subjects a person to undue burden. Before filing a motion pursuant to division (c)(3)(d) of this rule, a person resisting discovery under this rule shall attempt to resolve any claim of undue burden through discussions with the issuing attorney. A motion filed pursuant to division (c)(3)(d) of this rule shall be supported by an affidavit of the subpoenaed person or a certificate of that person's attorney of the efforts made to resolve any claim of undue burden. If a motion is made under division (c)(3)(c) or (c)(3)(d) of this rule, the court shall quash or modify the subpoena unless the party in whose behalf the subpoena is issued shows a substantia! need for the testimony or material that cannot be otherwise met without undue hardship and assures that the person to whom the subpoena is addressed will be reasonably compensated CIVIL RULE 45 (D) DUTIES IN RESPONDING TO SUBPOENA. A person responding to a subpoena to produce documents shall, at the person's option, produce them as they are kept in the usual course of business or organized and labeled to correspond with the categories in the subpoena. A person producing documents or electronically stored information pursuant to a subpoena for them shall permit their inspection and copying by all parties present at the time and place set in the subpoena for inspection and copying. If a request does not specify the form or forms for producing electronically stored information, a person responding to a subpoe- na may produce the information in a form or forms in which the information is ordinarily maintained if that form is reasonably useable, or in any form that is reasonably useable. Unless ordered by the court or agreed to by the person subpoenaed, a person responding to a subpoena need not produce the same electronically stored information in more than one form. Aperson need not provide discovery of electronically stored information when the production imposes undue burden or expense. On motion to compel discovery or for a protective order, the person from whom electronically stored information is sought must show that the information is not reasonably accessible because of undue burden or expense. !f a showing of undue burden or expense is made, the court may nonetheless order production of electronically stored information if the requesting party shows good cause. The court shall consider the factors in civ. R. 26(b)(4) when determining if good cause exists. In ordering production of electronically stored information, the court may specify the format, extent, timing, allocation of expenses and other conditions for the discovery of the electronically stored information. When information subject to a subpoena is withheld on a claim that it is privileged or subject to protection as trial preparation mate- tials, the claim shall be made expressly and shall be supported by a description of the nature of the documents, communications, or things not produced that is sufficient to enable the demanding party to contest the claim. if information is produced in response to a subpoena that is subject to a claim of privilege or of protection as trial-preparation materi- al, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a receiving party must promptly return, sequester, or destroy the specified information and any copies within the party's possession, custody or control. A party may not use or disclose the information until the claim is resolved. A receiving party may promptly present the information to the court under seal for a determination of the claim of privilege or of protection as trial-preparation material. If the receiving party disclosed the information before being notified, it must take reasonable steps to retrieve it The person who produced the information must preserve the information until the claim is resolved. OC-DR-82 (Rev. 9-2018) Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832 0G278 - T8 EXHIBIT 3 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832 0G278 = of B@reo srarEes Ss POSTAL SERVICE February 23, 2023 Dear Leigh Joyce: The following is in response to your request for proof of delivery on your item with the tracking number: 9171 9690 0935 0255 2941 14. Status: Delivered, Front Desk/Reception/Mail Room Status Date / Time: February 23, 2023, 9:57 am Location: CHICAGO, IL 60606 Postal Product: First-Class Mail® Extra Services: Certified Mail™ Return Receipt Electronic Signature of Recipient: See Conse ting Seep! Corals Address of Recipient: 4 C15 | Pelkey SO Note: Scanned image may reflect a different destination address due to Intended Recipient's delivery instructions on file. Thank you for selecting the United States Postal Service® for your mailing needs. If you require additional assistance, please contact your local Post Office™ or a Postal representative at 1-800-222-1811. Sincerely, United States Postal Service® 475 L'Enfant Plaza SW Washington, D.C. 20260-0004 v= Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Feb 24 3:11 PM-21CV006832 0G278 - T87 9171 9690 0935 0255 2941 14 Higih Street, Suite 1 0 Taft/ bi ol 43215 221.2838 | Fax 2007 Leigh B. Joyce 614.334.6164 ljoyce@taftiaw.com February 21, 2023 BY CERTIFIED MAIL RETURN RECEIPT REQUESTED Segal Consulting 101 North Wacker Drive Suite 500 Chicago, IL 60606-1724 Re: Dean Dennis, et al. v. State Teachers Retirement Board Franklin County, Ohio, Court of Common Pleas Case No. 21 CV 006832 To Whom It May Concern: Please find enclosed with this correspondence a Civil Action Cover Sheet in the Circuit Court of Cook County, Illinois, IL Sup. Ct, Rule 204 Subpoena for a Foreign Action Cover Sheet, and Circuit Court of Cook County, Illinois, Subpoena in a Civil Matter with corresponding attachments. Please let me know if you have any questions concerning this subpoena. Thank you for your attention to this matter. D Si cerely, G enon o Leigh B. Joyce LBJ Enclosures 764625811 Tall Stettinus § Hollisios LLP 7 altas.com 7 The Moder ow Em