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SUBP-035
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Steven Wieland
MOONEY WIELAND WARREN
512 W. Idaho St., Suite 103
Boise, Idaho 83702
TELEPHONE NO.: 208-401-9219 FAX NO.:
E-MAIL ADDRESS: steven.wieland.service@mooneywieland.com
ATTORNEY FOR (Name): Plaintiff/Counterdefendant
Court for county in which discovery is to be conducted:
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
STREET ADDRESS: 720 9th Street
MAILING ADDRESS: 720 9th Street
CITY, STATE, AND ZIP CODE: Sacramento, CA 95833
BRANCH NAME: Civil Division
Court in which action is pending:
Name of Court: THIRD JUDICIAL DISTRICT OF IDAHO, CANYON COUNTY
STREET ADDRESS: 1115 Albany St., Caldwell, ID 83605
MAILING ADDRESS: 1115 Albany St.
CITY, STATE, AND ZIP CODE: Caldwell, ID 83605
COUNTRY: United States
PLAINTIFF/PETITIONER: Third Eye Development, Inc. CALIFORNIA CASE NUMBER (if any assigned by court):
DEFENDANT/RESPONDENT: Renee Lyn Ralls Sill, et al. 24¢Vpps529g
SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS T LT L PTG WAl
IN ACTION PENDING OUTSIDE CALIFORNIA CV14-23-02829
THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, if known):
GOOGLE LLC at c/o CORPORATION SERVICE COMPANY, 2710 GATEWAY OAKS DR. STE 150N, SACRAMENTO, CA 95833
1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item 3, as follows:
To (name of deposition officer): GOOGLE LLC
On (date): Within 30 days of issuance of Subpoena At (time): nla
Location (address): 512 W. Idaho St., Suite 103, Boise, ID 83702 or steven.wieland.service@mooneywieland.com
Do not release the requested records to the deposition officer prior to the date and time stated above.
a. [__] by delivering a true, legible, and durable copy of the business records described in item 3, enclosed in a sealed inner
wrapper with the title and number of the action, name of witness, and date of subpoena clearly written on it. The inner
wrapper shall then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposition officer at the
address in item 1.
b. [x] by delivering a true, legible, and durable copy of the business records described in item 3 to the deposition officer at
the witness's address, on receipt of payment in cash or by check of the reasonable costs of preparing the copy, as
determined under Evidence Code section 1563(b).
c. [] by making the original business records described in item 3 available for inspection at your business address by the
attorney's representative and permitting copying at your business address under reasonable conditions during normal
business hours.
The records are to be produced by the date and time shown in item 1 (but not sooner than 20 days after the issuance of the
deposition subpoena, or 15 days after service, whichever date is later). Reasonable costs of locating records, making them
available or copying them, and postage, if any, are recoverable as set forth in Evidence Code section 1563(b). The records must
be accompanied by an affidavit of the custodian or other qualified witness pursuant to Evidence Code section 1561.
The records to be produced are described as follows (if electronically stored information is demanded, the form or forms in which
each type of information is to be produced may be specified):
See attached Schedule A. Attachment 3
[(x7] Continued on Attachment 3 (use form MC-025).
Attorneys of record in this action or parties without attorneys are (name, address, telephone number, and name of party
represented): Steven Wieland, Mooney Wieland Warren, 512 W. Idaho, Ste 103, Boise, Idaho 83702, 208-401-9219 (for Plaintiff);
Greg Chaney, Chaney Law Office, P.O. Box 489, Caldwell, Idaho 83606, 208-314-3850 (for R. Sill and Trust);
[x] Continued on Attachment 4 (use form MC-025).
Page 1 of 2
Code of Civil Procedure, §§ 2029.100-2029.900,
Form Adopted for Mandatory Use
Judicial Council of California
UBPOENA FOR PRODUCTION OF BUSINESS RECORDS 2020.410-2020.440;
SUBP-035 [Rev. January 1, 2012) IN ACTION PENDING OUTSIDE CALIFORNIA Government Code, § 68097.1
www.courts.ca.gov
SUBP-035
PLAINTIFF/PETITIONER: Third Eye Development, Inc. CASE NUMBER (of action pending outside California):
DEFENDANT/RESPONDENT: Renee Lyn Ralls Sill, et al. CV14-23-02829
5. If you have been served with this subpoena as a custodian of consumer or employee records
under Code of Civil
Procedure section 1985.6 and a motion to quash or an objection has been served on you, a
court order or agreement of
the parties, witnesses, and consumer or employee affected must be obtained before you are required
to produce
consumer or employee records.
6. [__] Other terms or provisions from out-of-state subpoena, if any (specify):
] Continued on Attachment 6 (use form MC-025).
DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT, YOU WILL ALSO BE
LIABLE
FOR THE SUM OF $500 AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
Date issued: MAR 2 1 2024
R. CADDICK > R. CADDICK
(TYPE OR PRINT NAME)
(SIGNATURE OF PERSON ISSUING SUBPOENA)
DEPUTY CLERK
(TITLE)
PROOF OF SERVICE OF SUBPOENA FOR
PRODUCTION OF BUSINESS RECORDS
1. | served this Subpoena for Production of Business Records In Action Pending Outside California by personally delivering a
copy to the person served as follows:
a. Person served (name):
b. Address where served:
c. Date of delivery: d. Time of delivery:
e. Witness fees and mileage both ways (check one):
(1) ] werepaid. Amount:............. $
(2) ] were not paid.
(3) [] were tendered to the witness's public entity employer as required by Government Code section 68097.2. The
amount tendered was (specify): $
f. Feeforservice:...................... ... $
| received this subpoena for service on (date):
3. [ ! also served a completed Proof of Service of Notice to Consumer or Employee and Objection (form SUBP-025)
by personally delivering a copy to the person served as described in 1 above.
4. Person serving:
a. [__] Notaregistered California process server
b. [ california sheriff or marshal
¢. [_] Registered California process server
d. [_] Employee or independent contractor of a registered California process server
e. [_] Exempt from registration under Business and Professions Code section 22350(b)
f. [_] Registered professional photocopier
g. [_] Exempt from registration under Business and Professions Code section 22451
h. Name, address, telephone number, and, if applicable, county of registration and number:
| declare under penalty of perjury under the laws of the State of (For California sherlff.or marshal use only)
California that the foregoing is true and correct. | certify that the foregoing is true and correct.
Date: Date:
(SIGNATURE) (SIGNATURE)
SUBP-035
[ [Rev. January 1, 2012]) SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS PR 2
IN ACTION PENDING OUTSIDE CALIFORNIA
MC-025
SHORT TITLE: CASE NUMBER:
[ Subpoena to Produce Documents, Attachment 3 (Schedule A)
ATTACHMENT (Number): 3
(This Attachment may be used with any Judicial Council form.)
Schedule A.
1. All documents related to any communications (including without limitation SMS and MMS messages,
voicemail recordings, and information stored in Subscriber’s Google Cloud account) between Subscriber and
the following persons/phone numbers during the Relevant Period including the content of the communications:
* Patti Syme (account may be listed under Scott Syme), 208-573-9300;
* David Ferdinand, 208-899-9232; and
* Rocky Hammons, 208-631-0732.
2. All Documents relating to Subscriber’s billing history during the Relevant Period including monthly
statements, payment details, and the identification and address of the Person making payments to Google. This
request DOES NOT seek the contents of any communication.
3. All Documents relating to Subscriber’s call history during the Relevant Period including the originating and
receiving phone numbers and date, time, and duration of all calls. This request DOES NOT seek the contents
of any communication.
4. All Documents relating to Subscriber’s text history during the Relevant Period including the originating and
receiving phone numbers and the date, time, and duration of all text exchanges. This request DOES NOT seek
the contents of any communication.
5. All Documents relating to Subscriber’s CDR Log for the Relevant Period including the originating and
receiving phone numbers and the date, time, and duration of all text exchanges. This request DOES NOT seek
the contents of any communication.
6. All Documents relating to Subscriber’s Google Cloud account for the Relevant Period including the
originating and receiving phone numbers and the date, time, and duration of all text exchanges. This request
DOES NOT seek the contents of any communication.
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page | of |
Attachment are made under penalty of perjury.) (Add pages as required)
Form Approved for Optional Use A'I'T ACHMENT www.courtinfo.ca.gov
Judicial Council of Califomia s °
MC-025 [Rev. July 1, 2009] to Judicial Council Form
MC-025
SHORT TITLE: CASE NUMBER:
[ Subpoena to Produce Documents: Attachment 4
ATTACHMENT (Number): 4
(This Attachment may be used with any Judicial Council form.)
Phillip Collaer, Anderson, Julian & Hull LLP, P.O. Box 7426, Boise, Idaho 83707, 208-344-5800 (for
Symeco, Inc., d/b/a Syme Real Estate and David Ferdinand);
Wyatt Johnson, Johnson May, 199 N. Capitol Blvd., Suite 200, Boise, ID 83702, 208-384-8588 (for Brett
Anderson and Lisa Parrish); and
Joshua Evett, Duke Evett, PLLC, P.O. Box 7387, Boise, Idaho 83707, 208-342-3310 (for Fathom Realty ID
LLC, d/b/a Fathom Realty and Rocky Hammons).
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page | of 1
Attachment are made under penalty of perjury.) (Add pages as required)
Form Approved for Optional Use ATT. ACHMENT www.courtinfo.ca.gov
Judicial Council of Califomnia Bk .
MC-025 [Rev. July 1, 2009] to Judicial Council Form
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SUBP-035 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Steven Wieland MOONEY WIELAND WARREN 512 W. Idaho St., Suite 103 Boise, Idaho 83702 TELEPHONE NO.: 208-401-9219 FAX NO.: E-MAIL ADDRESS: steven.wieland.service@mooneywieland.com ATTORNEY FOR (Name): Plaintiff/Counterdefendant Court for county in which discovery is to be conducted: SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO STREET ADDRESS: 720 9th Street MAILING ADDRESS: 720 9th Street CITY, STATE, AND ZIP CODE: Sacramento, CA 95833 BRANCH NAME: Civil Division Court in which action is pending: Name of Court: THIRD JUDICIAL DISTRICT OF IDAHO, CANYON COUNTY STREET ADDRESS: 1115 Albany St., Caldwell, ID 83605 MAILING ADDRESS: 1115 Albany St. CITY, STATE, AND ZIP CODE: Caldwell, ID 83605 COUNTRY: United States PLAINTIFF/PETITIONER: Third Eye Development, Inc. CALIFORNIA CASE NUMBER (if any assigned by court): DEFENDANT/RESPONDENT: Renee Lyn Ralls Sill, et al. 24¢Vpps529g SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS T LT L PTG WAl IN ACTION PENDING OUTSIDE CALIFORNIA CV14-23-02829 THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, if known): GOOGLE LLC at c/o CORPORATION SERVICE COMPANY, 2710 GATEWAY OAKS DR. STE 150N, SACRAMENTO, CA 95833 1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item 3, as follows: To (name of deposition officer): GOOGLE LLC On (date): Within 30 days of issuance of Subpoena At (time): nla Location (address): 512 W. Idaho St., Suite 103, Boise, ID 83702 or steven.wieland.service@mooneywieland.com Do not release the requested records to the deposition officer prior to the date and time stated above. a. [__] by delivering a true, legible, and durable copy of the business records described in item 3, enclosed in a sealed inner wrapper with the title and number of the action, name of witness, and date of subpoena clearly written on it. The inner wrapper shall then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposition officer at the address in item 1. b. [x] by delivering a true, legible, and durable copy of the business records described in item 3 to the deposition officer at the witness's address, on receipt of payment in cash or by check of the reasonable costs of preparing the copy, as determined under Evidence Code section 1563(b). c. [] by making the original business records described in item 3 available for inspection at your business address by the attorney's representative and permitting copying at your business address under reasonable conditions during normal business hours. The records are to be produced by the date and time shown in item 1 (but not sooner than 20 days after the issuance of the deposition subpoena, or 15 days after service, whichever date is later). Reasonable costs of locating records, making them available or copying them, and postage, if any, are recoverable as set forth in Evidence Code section 1563(b). The records must be accompanied by an affidavit of the custodian or other qualified witness pursuant to Evidence Code section 1561. The records to be produced are described as follows (if electronically stored information is demanded, the form or forms in which each type of information is to be produced may be specified): See attached Schedule A. Attachment 3 [(x7] Continued on Attachment 3 (use form MC-025). Attorneys of record in this action or parties without attorneys are (name, address, telephone number, and name of party represented): Steven Wieland, Mooney Wieland Warren, 512 W. Idaho, Ste 103, Boise, Idaho 83702, 208-401-9219 (for Plaintiff); Greg Chaney, Chaney Law Office, P.O. Box 489, Caldwell, Idaho 83606, 208-314-3850 (for R. Sill and Trust); [x] Continued on Attachment 4 (use form MC-025). Page 1 of 2 Code of Civil Procedure, §§ 2029.100-2029.900, Form Adopted for Mandatory Use Judicial Council of California UBPOENA FOR PRODUCTION OF BUSINESS RECORDS 2020.410-2020.440; SUBP-035 [Rev. January 1, 2012) IN ACTION PENDING OUTSIDE CALIFORNIA Government Code, § 68097.1 www.courts.ca.gov SUBP-035 PLAINTIFF/PETITIONER: Third Eye Development, Inc. CASE NUMBER (of action pending outside California): DEFENDANT/RESPONDENT: Renee Lyn Ralls Sill, et al. CV14-23-02829 5. If you have been served with this subpoena as a custodian of consumer or employee records under Code of Civil Procedure section 1985.6 and a motion to quash or an objection has been served on you, a court order or agreement of the parties, witnesses, and consumer or employee affected must be obtained before you are required to produce consumer or employee records. 6. [__] Other terms or provisions from out-of-state subpoena, if any (specify): ] Continued on Attachment 6 (use form MC-025). DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT, YOU WILL ALSO BE LIABLE FOR THE SUM OF $500 AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY. Date issued: MAR 2 1 2024 R. CADDICK > R. CADDICK (TYPE OR PRINT NAME) (SIGNATURE OF PERSON ISSUING SUBPOENA) DEPUTY CLERK (TITLE) PROOF OF SERVICE OF SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS 1. | served this Subpoena for Production of Business Records In Action Pending Outside California by personally delivering a copy to the person served as follows: a. Person served (name): b. Address where served: c. Date of delivery: d. Time of delivery: e. Witness fees and mileage both ways (check one): (1) ] werepaid. Amount:............. $ (2) ] were not paid. (3) [] were tendered to the witness's public entity employer as required by Government Code section 68097.2. The amount tendered was (specify): $ f. Feeforservice:...................... ... $ | received this subpoena for service on (date): 3. [ ! also served a completed Proof of Service of Notice to Consumer or Employee and Objection (form SUBP-025) by personally delivering a copy to the person served as described in 1 above. 4. Person serving: a. [__] Notaregistered California process server b. [ california sheriff or marshal ¢. [_] Registered California process server d. [_] Employee or independent contractor of a registered California process server e. [_] Exempt from registration under Business and Professions Code section 22350(b) f. [_] Registered professional photocopier g. [_] Exempt from registration under Business and Professions Code section 22451 h. Name, address, telephone number, and, if applicable, county of registration and number: | declare under penalty of perjury under the laws of the State of (For California sherlff.or marshal use only) California that the foregoing is true and correct. | certify that the foregoing is true and correct. Date: Date: (SIGNATURE) (SIGNATURE) SUBP-035 [ [Rev. January 1, 2012]) SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS PR 2 IN ACTION PENDING OUTSIDE CALIFORNIA MC-025 SHORT TITLE: CASE NUMBER: [ Subpoena to Produce Documents, Attachment 3 (Schedule A) ATTACHMENT (Number): 3 (This Attachment may be used with any Judicial Council form.) Schedule A. 1. All documents related to any communications (including without limitation SMS and MMS messages, voicemail recordings, and information stored in Subscriber’s Google Cloud account) between Subscriber and the following persons/phone numbers during the Relevant Period including the content of the communications: * Patti Syme (account may be listed under Scott Syme), 208-573-9300; * David Ferdinand, 208-899-9232; and * Rocky Hammons, 208-631-0732. 2. All Documents relating to Subscriber’s billing history during the Relevant Period including monthly statements, payment details, and the identification and address of the Person making payments to Google. This request DOES NOT seek the contents of any communication. 3. All Documents relating to Subscriber’s call history during the Relevant Period including the originating and receiving phone numbers and date, time, and duration of all calls. This request DOES NOT seek the contents of any communication. 4. All Documents relating to Subscriber’s text history during the Relevant Period including the originating and receiving phone numbers and the date, time, and duration of all text exchanges. This request DOES NOT seek the contents of any communication. 5. All Documents relating to Subscriber’s CDR Log for the Relevant Period including the originating and receiving phone numbers and the date, time, and duration of all text exchanges. This request DOES NOT seek the contents of any communication. 6. All Documents relating to Subscriber’s Google Cloud account for the Relevant Period including the originating and receiving phone numbers and the date, time, and duration of all text exchanges. This request DOES NOT seek the contents of any communication. (If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page | of | Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use A'I'T ACHMENT www.courtinfo.ca.gov Judicial Council of Califomia s ° MC-025 [Rev. July 1, 2009] to Judicial Council Form MC-025 SHORT TITLE: CASE NUMBER: [ Subpoena to Produce Documents: Attachment 4 ATTACHMENT (Number): 4 (This Attachment may be used with any Judicial Council form.) Phillip Collaer, Anderson, Julian & Hull LLP, P.O. Box 7426, Boise, Idaho 83707, 208-344-5800 (for Symeco, Inc., d/b/a Syme Real Estate and David Ferdinand); Wyatt Johnson, Johnson May, 199 N. Capitol Blvd., Suite 200, Boise, ID 83702, 208-384-8588 (for Brett Anderson and Lisa Parrish); and Joshua Evett, Duke Evett, PLLC, P.O. Box 7387, Boise, Idaho 83707, 208-342-3310 (for Fathom Realty ID LLC, d/b/a Fathom Realty and Rocky Hammons). (If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page | of 1 Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use ATT. ACHMENT www.courtinfo.ca.gov Judicial Council of Califomnia Bk . MC-025 [Rev. July 1, 2009] to Judicial Council Form