EFiled: Nov 28 2017 10:55ANk
`Transaction ID 61398239
`Case No. Multi-Case
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`Exhibit A 
`Exhibit A
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`EFiled: Nov 28 2017 10:55AM EST
`Transaction ID 61398239
`Case No. Multi-Case
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`IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
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`In re
`STARZ STOCKHOLDER LITIGATION
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`In re
`STARZ APPRAISAL
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`CONSOLIDATED
`C.A. No. 12584-VCG
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`CONSOLIDATED
`C.A. No. 12968-VCG
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`SUBPOENA DUCES TECUM
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`TO: Goldman Sachs & Co. LLC
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`ATTN: Head of Litigation and Reg.
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`200 West Street
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`New York, NY 10282
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`This subpoena is issued under Court of Chancery Rule 45. Court of Chancery
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`Rules 45(c) and (d), attached hereto, set forth the protections and duties with respect
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`to this Subpoena.
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`YOU ARE HEREBY COMMANDED to produce the documents requested
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`in Schedule A, attached hereto, on or before December 12, 2017, at the offices of
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`Chipman Brown Cicero & Cole LLP, 501 Fifth Avenue, 15th Floor, New York, NY
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`10017, or such other location or date as may be agreed by the parties or ordered by
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`the Court.
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`Pursuant to Court of Chancery Rule 45, subdivisions (c) and (d) of Rule 45
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`are as follows:
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`(c) Protection of persons subject to subpoenas.
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`(1) A party 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. The court on behalf of which the subpoena was issued shall
`enforce this duty and may impose upon the party or attorney in breach of this duty
`an appropriate sanction, which may include, but is not limited to, lost earnings and
`a reasonable attorney’s fee.
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`(2)(A) A person commanded to produce and permit inspection and copying of
`designated documents, electronically stored information, or tangible things or
`inspection of premises need not appear in person at the place of production or
`inspection unless commanded to appear for deposition, hearing or trial.
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`(B) Subject to paragraph (d)(2) of this rule, a person commanded to produce and
`permit inspection and copying may, within 14 days after service of the subpoena or
`before the time specified for compliance if such time is less than 14 days after
`service, serve upon the party or attorney designated in the subpoena written
`objection to inspection or copying of any or all of the designated materials or of the
`premises. If objection is made, the party serving the subpoena shall not be entitled
`to inspect and copy the materials or inspect the premises except pursuant to an order
`of the court by which the subpoena was issued. If objection has been made, the party
`serving the subpoena may, upon notice to the person commanded to produce, move
`at any time for an order to compel production. Such 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 inspection and copying commanded.
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`(3)(A) On timely motion, the court on behalf of which the subpoena was issued shall
`quash or modify the subpoena if it
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`(i) fails to allow reasonable time for compliance;
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`(ii) requires disclosure of privileged or other protected matter and no exception or
`waiver applies; or
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`(iii) subjects a person to undue burden.
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`(B) If a subpoena
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`2
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`(i) requires disclosure of a trade secret or other confidential research, development,
`or commercial information, or
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`(ii) requires disclosure of an unretained expert’s opinion or information not
`describing specific events or occurrences in dispute and resulting from the expert’s
`study made not at the request of any party, the court on behalf of which the subpoena
`was issued may, to protect a person subject to or affected by the subpoena, quash or
`modify the subpoena or, if the party in whose behalf the subpoena is issued shows a
`substantial 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, the Court may order appearance or production only
`upon specified conditions.
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`(d) Duty in responding to subpoena.
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`(1) If a subpoena does not specify a form for producing documents or electronically
`stored information, the person responding shall produce it in a form or forms in
`which it is ordinarily maintained, or in which it is reasonably usable. Absent a
`showing of good cause, the person responding need not produce the same documents
`or electronically stored information in more than one form. The person responding
`need not provide discovery of documents or electronically stored information from
`sources that the person identifies as not reasonably accessible because of undue
`burden or cost. On a motion to compel discovery or for a protective order, the person
`responding to a subpoena must show that the information is not reasonably
`accessible because of undue burden or cost. If that showing is made, the Court
`nevertheless may order discovery from such sources if the requesting party shows
`good cause. The Court may specify the conditions for the discovery.
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`(2) When information subject to a subpoena is withheld on a claim that it is
`privileged or subject to protection as trial preparation materials, the claim shall be
`made expressly and shall be supported by a description of the nature of the
`documents, electronically stored information, or tangible things not produced that is
`sufficient to enable the demanding party to contest the claim.
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`DATED: November 28, 2017
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`CHIPMAN BROWN CICERO & COLE, LLP
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` /s/ Stephanie S. Habelow
`Paul D. Brown (#3903)
`Stephanie S. Habelow (#5184)
`Hercules Plaza
`1313 North Market Street, Suite 5400
`Wilmington, DE 19801
`Telephone: (302) 295-0191
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`Conflicts Counsel for Respondent Starz
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`4
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