The Law Firm of Blair B. Chintella

Discovery

The Federal Rules of Civil Procedure are the primary source of rules governing the discovery process in federal courts. Mr. Patel was given an extremely short period of time (only 2 months) to accomplish as much discovery as possible to try and uncover how he was caught up in a complex scheme involving offshore shell companies and potentially forged documents.

Subpoenas

Interrogatories

Requests for Admission

Production of Documents

Depositions by Oral Examination




Subpoenas --- Rule 45

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Numerous subpoenas were served across the country revealing important information, for instance, audio recordings of customer service calls to GoDaddy revealed John Steele posing as Alan Cooper and Mark Lutz. Enforcement of the subpoenas is ongoing.

Download All Subpoenas:
Date Target
Production/Notes
July 10, 2012 Comcast
July 10, 2013 Domains by Proxy, LLC
July 10, 2013 GoDaddy.com, LLC
July 15, 2013 Comcast
July 15, 2013 Cox Communications
July 25, 2013 Comcast
July 25, 2013 Cox Communications
July 25, 2013 Right Ascension, Inc.
July 25, 2013 Whois Privacy Protection Services, Inc.
July 26, 2013 CD Universe
August 4, 2013 Paul Hansmeier
August 4, 2013 Mark Lutz
August 6, 2013 Heartbreaker Digital, LLC
August 7, 2013 Heartbreaker Digital, LLC
August 7, 2013 BizXpress, LLC
August 8, 2013 Comcast
August 8, 2013 International Video Distributors, LLC
August 16, 2013 Google
August 20, 2013 Atlantic Broadband (Miami), LLC
August 20, 2013 Domains by Proxy, LLC
August 20, 2013 Google

Interrogatories --- Rule 33

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Date Title
Production
July 17, 2013 First Interrogatories No response or not properly served.
July 30, 2013 Second Interrogatories No response or not properly served.


Requests for Admission --- Rule 36

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Date Title
Production
July 30, 2013 Revised First RFAs
July 30, 2013 Second RFAs No response or not properly served.
August 2, 2013 Third RFAs No response or not properly served.


Production of Documents --- Rule 34

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Date Title
Production
July 17, 2013 First RFPs No response or not properly served.
July 30, 2013 Second RFPs No response or not properly served.
July 31, 2013 Third RFPs No response or not properly served.


Depositions Upon Oral Examination --- Rule 30

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Deposition Date Deponent
Notice
Transcript
August 21, 2013 Mark Lutz
September 3, 2013 AF Holdings, LLC

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