FILED
`3/8/2024 10:32 AM
`FELICIA PITRE
`DISTRICT CLERK
`DALLAS CO., TEXAS
`Kryshawna Charleston DEPUTY
`
`Cause No. DC-23-06332
`
`IN THE DISTRICT COURT
`
`1918? JUDICIAL DISTRICT
`
`DALLAS COUNTY, TEXAS
`
`§
`
`§ §
`
`§§
`
`§ §
`
`§ §
`
`§
`
`HARRIS F. UNDERWOOD,IT, INC.
`NKA CH2, INC.,
`
`Plaintiff
`
`Vv.
`
`STEVEN SUTCLIFFE,
`
`Defendant
`
`NOTICE OF INTENT TO SERVE SUBPOENA DUCES TECUM ON
`NON-PARTY WOOD-WILSON COMPANY,INC.
`
`TO: Wood-Wilson Company,Inc., by and throughits registered agent, C T Corporation System,
`1999 Bryan St., Ste. 900, Dallas, TX 75201.
`
`COME NOW Harris F. Underwood,III, Inc., n/k/a CH2, Inc. (“Plaintiff’ or “Requesting
`
`Party”), Plaintiffs in the above-styled and numbered cause, and serve the following Notice of Intent
`
`to Serve Subpoena Duces Tecum on Non-Party WOOD-WILSON COMPANY,
`
`INC.
`
`(“Responding Party”). Pursuant to Rule 205 of the Texas Rules of Civil Procedure, notice is hereby
`
`given that Plaintiff intends to serve the Subpoenaattached hereto as “Exhibit A”, compelling the
`
`production of documents or tangible evidence within the possession, custody, or control of
`
`Responding Party not less than ten (10) days from the date of this Notice. The documents to be
`
`producedare identified in, and attached to the Subpoenaas Exhibit “1” to Exhibit A. Responding
`
`Party is requested to appear at the offices of Preferred Legal Services, Inc., 10601 LBJ Freeway,
`
`Suite 509, Mesquite, Texas 75150, no later than twenty (20) days after service of the Subpoena
`
`calling for the production of such documents and/or tangible evidence to take the Deposition on
`
`Written Question attached as Exhibit “2” to Exhibit A and sign it before a notary.
`
`In the
`
`alternative, Responding Party may complete and sign the Deposition on Written Questions before
`
`NOTICE OF INTENT TO SERVE SUBPOENA
`
`1
`
`

`

`a notary and sendit with the responsive documents to the offices of Holmgren Johnson: Mitchell
`
`Madden, LLP, 12801 N. Central Expressway, Suite 140 Dallas, Texas 75243.
`
`HOLMGREN, JOHNSON: MITCHELL
`MADDEN, LLP
`
`/s/ Mitchell Madden
`Mitchell Madden
`State Bar No. 12789350
`mmadden@hjmmlegal.com
`Dennis M. Holmgren
`State Bar No. 24036799
`dennis@hjmmlegal.com
`
`12801 N. Central Expressway, Ste. 140
`Dallas, Texas 75243
`Tele: 972/484-7780
`Fax: 972/484-7743
`
`ATTORNEYSFOR PLAINTIFFS
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that the foregoing document has been served, pursuant to Tex.
`R. Civ. P. 21a, on all counsel and parties of record on this 8" day of March, 2024.
`
`/s/ Mitchell Madden
`Mitchell Madden
`
`NOTICE OF INTENT TO SERVE SUBPOENA
`
`

`

`EXHIBIT A
`
`Cause No. DC-23-06332
`
`IN THE DISTRICT COURT
`
`1918" JUDICIAL DISTRICT
`
`DALLAS COUNTY, TEXAS
`
`§
`
`§ §
`
`§§
`
`§ §
`
`§ §
`
`§
`
`HARRIS F. UNDERWOOD,IL, INC.
`NKA CH2, INC.,
`
`Plaintiff
`
`Vv.
`
`STEVEN SUTCLIFFE,
`
`Defendant
`
`THE STATE OF TEXAS
`
`SUBPOENA DUCES TECUM
`PURSUANT TO RULE 176 OF THE TEXAS RULES OF CIVIL PROCEDURE
`
`TO ANY SHERIFF OR CONSTABLE OF THE STATE OF TEXAS OR OTHER
`PERSON AUTHORIZED TO SERVE AND EXECUTE SUBPOENASAS PROVIDED IN
`
`TEX.R.CIV.P. 176.5 OF THE TEXAS RULES OF CIVIL PROCEDURE
`
`YOU ARE HEREBY COMMANDED TO SUMMON:
`
`Wood-Wilson Company,Inc. (Respondent)
`by and throughits registered agent
`C T Corporation System
`1999 Bryan St., Ste. 900
`Dallas, TX 75201
`
`and whois represented to reside or have a place of business within one hundredfifty (150) miles
`of Preferred Legal Services, Inc., 10601 LBJ Freeway, Suite 509, Mesquite, Texas 75150, in which
`the above styled and numberedsuit is pending or who may be found within such distance at the
`time of service, to be and appear at the offices of Preferred Legal Services, Inc., 10601 LBJ
`Freeway, Suite 509, Mesquite, Texas 75150, within twenty (20) days to produce documents
`responsive to the requests attached hereto as and contained in Exhibit “1” and respond to the
`deposition on written questions attached hereto as and contained in Exhibit “2” in connection with
`the lawsuit styled Harris F. Underwood, LIL, Inc., n/k/a CH2, Inc. v. Steven Sutcliffe, in the 191*
`Judicial District, Dallas County, Texas.
`
`Alternatively, Respondent may produce the documents responsive to Exhibit “1” and
`complete the written questions propounded in Exhibit “2” before a notary, have it notarized, and
`return same along with the responsive documents to the offices of HOLMGREN JOHNSON:
`
`SUBPOENA DUCES TECUM
`
`1
`
`

`

`MITCHELL MADDEN,LLP, 12801 N. Central Expressway, Suite 140, Dallas, Texas 75243
`within twenty (20) days of service hereof.
`
`DO NOT FAILto return this writ to said Court, with return thereon, showing the manner
`of execution.
`
`FAILURE OF ANY PERSON WITHOUT ADEQUATE EXCUSE TO OBEY A
`SUBPOENA SERVE ON THAT PERSON MAY BE DEEMED A CONTEMPT OF THE
`COURT FROM WHICH THE SUBPOENAIS ISSUED OR A DISTRICT COURTIN THE
`COUNTY IN WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED BY
`FINE OR CONFINEMENT, OR BOTH.
`
`This Subpoena Duces Tecum is issued at the instance of Plaintiff Harris F. Underwood,III,
`Inc., n/k/a CH2, Inc. by and through its attorneys of record Mitchell Madden and Dennis
`Holmgren, HOLMGREN JOHNSON: MITCHELL MADDEN, LLP,
`12801 N. Central
`Expressway, Suite 140, Dallas, Texas 75243.
`
`Date of Issuance:
`
`, 2024.
`
`SUBPOENAISSUED BY:
`
`HOLMGREN, JOHNSON: MITCHELL
`MADDEN, LLP
`
`/s/ Mitchell Madden
`Mitchell Madden
`State Bar No. 12789350
`mmadden@hjmmlegal.com
`Dennis M. Holmgren
`State Bar No. 24036799
`dennis@hjmmlegal.com
`
`North Central PlazaIII
`12801 N. Central Expressway, Suite 140
`Dallas, Texas 75243
`Tele: 972/484-7780
`Fax: 972/484-7743
`
`ATTORNEYSFOR PLAINTIFF
`
`SUBPOENA DUCES TECUM
`
`2
`
`

`

`WITNESS SUBPOENA/ SUBPOENA DUCES TECUM
`
`RETURN
`
`o'clock —_—s.M.,
`, 2024,at
`Cametohandthe _ day of
`
`day of
`2024, at
`o’clock _.M., by delivering
`and executed the
`
`to the within named _
`in person at
`in County, Texas, a true copy of this
`
`Subpoena,and tendering said witness the sum of $
`
`
`
`By Deputy:
`
`Sheriff/Constable
`
`
`County, Texas
`
`OR
`
`
`
`By:
`Person whois not a party to the suit, and is not less than 18 years
`of age.
`
`ACCEPTANCEOF SERVICE OF SUBPOENA BY WITNESS PER RULE176 T.R.C.P.
`
`I the undersigned witness named in the Subpoena acknowledge receipt of a copy thereof, and
`hereby acceptservice of the attached subpoena.
`
`Rule 176.8(a) Contempt. Failure by any person without adequate excuse to obey a subpoena
`served upon that person may be deemed a contemptof the court from which the subpoena
`is issued or a district court in the county in which the subpoena is served, and may be
`punished by fine or confinement, or both.
`
`
`
`SIGNATURE OF WITNESS
`
`DATE
`
`DEE 24 SIE RIE SR 2A ER SIC OE OR BR OF SEE I OIC ER BIC ER BE 24 SIE OR OIC SIR 2A CR SIC OE SIR IR OF SEE HI IC ER BIC OC BIC 24 SIE OR OE SIR IR CR BIC COIR IR OF SE A IC ER OIC OE BIC 24 OIE OC 2 SR IC IC BIC OC OC OK
`
`Not executed as to the witness for the following reasons:
`
`
`
`FEE OR SERVICE OF SUBPOENA:$
`
`SUBPOENA DUCES TECUM
`
`3
`
`

`

`EXHIBIT “1”
`
`Cause No. DC-23-06332
`
`IN THE DISTRICT COURT
`
`1915? JUDICIAL DISTRICT
`
`DALLAS COUNTY, TEXAS
`
`§ § § § § § § § § §
`
`HARRIS F. UNDERWOOD,II, INC.
`NKA CH2, INC.,
`
`Plaintiff
`
`v.
`
`STEVEN SUTCLIFFE,
`
`Defendant
`
`UEST FOR PRODUCTION TO WOOD-WILSON COMPANY, INC,
`RE
`
`The following items are to be produced for examination, copying, and inspection within
`twenty (20) days from service of this Subpoena Duces Tecum at the offices of Preferred Legal
`Services, Inc., 10601 LBJ Freeway, Suite 509, Mesquite, Texas 75150.
`
`Alternatively, WOOD-WILSON COMPANY,INC. (“Responding Party” or “You”) may
`produce the documents and/or records responsive to this Exhibit “1” and complete the written
`questions propounded in Exhibit “2” before a notary, have it notarized, and return same along
`with responsive documents to HOLMGREN JOHNSON: MITCHELL MADDEN,LLP, 12801 N.
`Central Expressway, Suite 140, Dallas, Texas 75243 within twenty (20) days of service hereof.
`
`INSTRUCTIONS
`
`A.
`
`Requests for Production.
`
`1.
`
`All documents are to be produced as they are kept in the usual course ofbusiness
`with any identifying labels, file markings, or similar identifying features, or
`shall be organized and labeled to correspond to the categories requested below.
`
`Unless otherwise stated herein, all documents requested are for the period
`commencing July 1, 2022 up to and including the dateoftrial.
`
`These requests call for the production of all responsive documents in your
`possession, custody, or control, or in the possession, custody, or control of your
`representatives, agents, or other persons acting on your behalf, without regard
`to the physical location of such documents.
`
`In responding to these requests, include documents obtained on your behalf by
`your counsel, representatives, agents, or any other personsacting on yourbehalf.
`Ifyour responseis that the documents are not within your possession or custody,
`describe in detail
`the unsuccessful efforts you made to locate each such
`
`Page |
`
`

`

`document. If your response is that documents are not under your control,
`identify who has the control and the location of the documents.
`
`If any document was, but no longer is, in your possession, subject to your
`control, or in existence, include a statement:
`
`(1)
`
`(11)
`
`identifying the document;
`
`describing where the documentis now;
`
`(iii)
`
`identifying who hascontrol of the document;
`
`(iv)
`
`(v)
`
`describing how the document becamelost or destroyed or was
`transferred; and,
`
`identifying each person responsible for or having knowledge of
`the loss, destruction, or transfer of this document from your
`possession, custody, or control.
`
`Each request contemplates production of all documents in their entirety. If a
`portion of a documentis responsive to one or more requests, the document shall
`be producedinits entirety.
`
`If you object to a request for production, please specifically state:
`
`(1)
`
`(11)
`
`the legal or factual basis for the objection; and,
`
`the extent to which you refuse to comply with the request.
`
`If you withhold any material or information responsive to these requests in
`whole or in part, for any reason including, without limitation, a claim of
`privilege or other protection from disclosure, you muststate:
`
`(1)
`
`that information or material responsive to the request has been
`withheld;
`
`(ii)
`
`the request to which the information or material relates; and,
`
`(iii)—the privilege or privileges asserted.
`
`To the extent you assert that a portion of the document should not be produced
`due to privilege and produce the non-privileged portions of the document,
`indicate the portion of the document withheld by stamping the words
`"MATERIAL REDACTED"on the document in an appropriate location that
`does not obscure the remaining text. Any redacted material should also be
`includedin the withholding statement described above.
`
`Page 2
`
`

`

`10.
`
`11.
`
`If there are no documents in response to any particular request, you shall state
`so in writing.
`
`Each page imageshall contain a footer or label with a sequentially ascending
`production or Bates number.
`
`DEFINITIONS
`
`The following terms shall have the meanings indicated below whethercapitalized or in
`bold. These definitions apply to all portions of this First Set of Requests for Production.
`
`The term “You,” “Your,” or “Wood-Wilson” shall collectively mean and refer to
`1.
`Wood-Wilson Company, Inc. and any agent, servants, employees, persons, attorney, or entity
`acting on its behalf.
`
`The term “Sutcliffe” or “Defendant” shall mean and refer to Defendant Steven
`2.
`Stucliffe and any agent, servant, employee, attorney, person, or entity acting on his behalf.
`
`The term “Plaintiff” or “Underwood”shall mean and refer to Harris F. Underwood,
`3.
`IU, Inc., n/k/a CH2, Inc. and any agent, servant, employee, or person acting on their behalf,
`including Chris Hill and Cash Harbaugh.
`
`4.
`
`5.
`
`“Hill” shall mean Chris Hill.
`
`“Harbaugh”shall mean Cash Harbaugh.
`
`The term “Lawsuit” shall mean and refer to the above-captioned andstyled case,
`6.
`Harris F. Underwood, LI, Inc., n/k/a CH2, Inc. v. Steven Sutcliffe, No. DC-23-06332, 191*
`District Court of Dallas County.
`
`Unless otherwise set forth herein, the terms in the Requests for Production shall be
`7.
`defined as set forth in the TAT SAMPLE PRODUCER AGREEMENTattached as Exhibit A
`hereto.
`
`The term “Producer Agreement” shall mean and refer to the TAT SAMPLE
`8.
`PRODUCER AGREEMENTexecuted on February 7, 2013, which is attached as Exhibit A.
`
`The term “Insgroup” shall mean and refer to Insgroup, Inc. and Insgroup, LLC and
`9.
`any successorthereto, and each of their agents, representatives, employees, attorneys, or entities
`acting on their behalf.
`
`The term “Baldwin” shall mean and refer to Baldwin Krystyn Sherman Partners,
`10.
`LLCandits agents, representatives, employees, attorneys, or entities acting on its behalf.
`
`Page 3
`
`

`

`The term “INSGROUP Lawsuit” shall mean and refer to Insgroup, Inc. v. Wood-
`11.
`Wilson Company, Inc., et al., Cause No. DC-20-16312 filed in the 101“ District Court, Dallas
`County, Texas.
`
`The term “HFU/Insgroup SPA” shall mean and refer to the Sale and Purchase
`12.
`Agreement between HFU, Harbaugh,and Hill as Sellers, and InsGroup, Inc. as Buyer, executed to
`be effective January 1, 2020.
`
`The term “Sutcliffe Accounts” shall mean and refer to the accounts listed on
`13.
`Schedule 5 of the HFU/Insgroup SPA, a copy of which is attached as Exhibit B.
`
`The term “Document” is synonymous in meaning and equal in scopeto its usage in
`14.
`TEX. R. CIV. P. 192.3(b), which includes “papers, books, accounts, drawings, graphs, charts,
`photographs, electronic or videotape recordings, data, and data compilations,” stored in any
`medium, electronic or otherwise, from which information can be obtained either directly or, if
`necessary, after translation by the responding party into a reasonably usable form. The term
`specifically includes all forms of electronically stored information (“ESI”), including magnetic
`data, as provided in TEX. R. CIV. P. 196.4. The term “document”refers to any documentor draft
`of a document now orat any time in your possession, custody, or control. A person is deemed in
`control of a documentif the person has any ownership, possession, or custody of the document, or
`the right to secure the documentor a copyof it from any person or public or private entity having
`physical possession of it. Included within this definition are messages sent by applications that
`automatically delete messages, such as WhatsApp, Snapchat, or CyberDust. Deleted documents
`are also included within the term “Documents.”
`
`The term “Communication” and “Correspondence” or any variant thereof, means
`15.
`any contact between two or more persons by which any information or knowledgeis transmitted
`or conveyed between two or more persons andshall include, without limitation, written contact by
`meanssuch as e-mails, text messages, social media correspondence,letters, or any other document
`(as defined above), and any oral contract,
`such as
`face-to-face meetings or
`telephone
`conversations.
`
`A reference to a person includes an individual, corporation, partnership, joint
`16.
`venture, limited liability company, governmental authority, unincorporated organization, trust,
`association, or other entity. Any reference to an individualor to an entity includesall that person's
`principals, employees, agents, attorneys, consultants, and other representatives.
`
`The terms “and” and “or” shall be construed either conjunctively or disjunctively
`17.
`as necessary to bring within the scope of the request all responses that might otherwise fall outside
`the scope of the request.
`
`The terms “all,” “any,” or “each” encompassall of the stated matter.
`
`The use of singular form includesplural, and vice versa.
`
`The use of present tense includes past tense, and vice versa.
`
`12.
`
`13.
`
`14.
`
`Page 4
`
`

`

`“concerning,” mean consisting of,
`“concer,”
`The term “Relate,” “relating,”
`15.
`referring to, reflecting, or being in any waylogically or factually connected with the stated matter.
`
`33
`
`66
`
`33
`
`66
`
`REQUEST FOR ELECTRONIC OR MAGNETIC DATA
`
`Requesting Party hereby requests the production of electronic or magnetic data, as follows:
`
`Requesting Party requests that Responding Party produce responsiveelectronically
`1.
`stored information (ESI) in its native form, which means the form in which the information was
`customarily created, used, and stored by the native application employed by the producing
`party in the ordinary course of business.
`
`If the Responding Party cannot--through reasonable efforts--retrieve the data or
`2.
`information requested or produceit in its native form, such information may be produced in an
`agreed upon near native form, which means a form in which the item can be imported into the
`native application without a material
`loss of content, structure or functionality as compared to
`the native form. Static image production formats serve as near-native alternatives only for
`information items
`that are natively static images (i.e., photographs and scans of hard-copy
`documents).
`
`
`
`
`
`
`
`3.
`Requesting Party requests native or near-native forms of documents as follows:
`
`
`
`Source ESI
`Native or Near-Native Form or Forms Sought
`
`Microsoft Word Documents
`.DOC, .DOCX
`
`Microsoft Excel Spreadsheets
`XLS, XLSX
`
`Microsoft PowerPoint Presentations
`.PPT, .PPTX
`Microsoft Access Databases
`.MDB, .ACCDB
`
`WordPerfect Documents
`.WPD
`
`Portable Document Format
`.PDF
`
`Photographs
`JPG
`
`Quickbooks
`.QBB
`Email
`Requesting Party requests that individual messages be
`produced in a form or form that is readily importable
`into standard e-mail client programs and should
`adhere to the specifications set forth in RFC 5322,
`which is the internet email standard. For Microsoft
`Exchange or Outlook messaging, Requesting Party
`requests production in .PST format with the source
`foldering data preserved and produced, if originally
`organized by folder structure,.
`For Lotus Notes,
`Requesting Party requests that Responding Party
`produce data in .PST format. For internet mail, such
`as Gmail or Yahoo Mail, Requesting Party requests
`that the messages and associated folder structure, if
`originally
`organized
`by
`folder
`structure,
`be
`downloaded via IMAP and produced as one (1) or
`
`Page 5
`
`

`

`
`
`
`
`
`
`
`
`If Responding Party’s workflow
`more .PST files.
`requires that attachments be extracted and produced
`separately
`from the
`transmitting messages,
`attachments should be produced in their native format
`with parent/child relationships to the message and
`container(s) preserved and producedin a load file.
`
`For information contained within databases, Requesting Party requests that
`4.
`Responding Party produce responsive information through: (i) the use of standardized reports
`which can be generated in the ordinary course of business without specialized programming
`efforts beyond those necessary to generate standard reports, or (11) specialized reports that are
`used by Responding Party in its ordinary course of business. All such reports shall be produced
`in a delimited electronic format preserving field and record structures and names.
`
`require redaction,
`that
`For Information items that are paper documents or
`5.
`Requesting Party requests that Responding Party produce such documents in static image formats
`scanned at 300 dpi e.g. as either single page Group IV TIFF files or multipage PDF images.
`For multi-page .PDF files,
`the Requesting Party requests that each individual document be
`produced as a single file rather than multiple documents being aggregated into one (1) or more
`single files.
`If an Information Item contains color, the Requesting Party requests that the
`Responding Party produce such item in a formatthat displays the original color. Requesting Party
`requests that redactions be logged along with other information items withheld on claims of
`privilege.
`
`For individual Information Items requiring redaction Requesting Party requests
`6.
`that Responding Party (as feasible) produce such Information Items in .PDF format, redacted
`natively using: (i) the Adobe Acrobat or Nitro redaction feature, or (ii) redacted and produced
`in a format that does not serve to downgradethe ability to electronically search the unredacted
`portions of the item.
`
`If Responding Party uses a document review or E-Discovery platform, such as
`7.
`Concordance, Summation, Relativity, Eclipse, etc., Requesting Party requests that the Information
`Items be produceddirectly from such system as follows: (i) text searchable .PDF files unitized at
`the documentlevel (i.e., each .PDF represents a single document); (11) native files included; (111)
`any OCRdata included; (iv) load file in Concordance (.DAT) format, and (v) Concordance Image
`or Opticon (.OPT) cross referencefiles.
`
`Forload files, Requesting Party requests that such files be organized as follows: (i)
`8.
`the first line must be a headerthat identifies each field name,(ii) the DAT file must use the standard
`Concordance default field limiters- Comma ASCII character (020), Quote b ASCII character
`(254), (111) date fields should be formatted mm/dd/yy, (iv) date and time should be a single field,
`(v) all data fields should be exported, (vit) BEGDOC and END DOCshould be two (2) separate
`fields, (viii) BEGATTACH and ENDATTACHshould be two (2) separate fields, (4x) email
`attachment fields must be included to preserve the parent/child relationship between emails and
`
`Page 6
`
`

`

`their attachments, and (x) an OCRPATHfield should be included and linked to separate OCR text
`files rather than includedin the loadfile.
`
`Requesting Party requests that documents be producedviaflash drive, external hard
`9.
`drive, or file sharing site, as appropriate. Upon request, Requesting Party will provide access to
`a document share at docs.hjmmlegal.com so that files can be uploaded. File and folder names
`should not contain embedded spaces or special characters.
`If productions are compressed, the
`production should be produced in .ZIP format. All electronic productions should be free of
`computer viruses. Requesting Party requests that Responding Party provide any accesscredentials
`or passwords to Requesting Party via electronic mail.
`
`REQUESTS FOR PRODUCTION
`
`REQUEST FOR PRODUCTION NO.1: Produce the Settlement Agreement entered into by
`You in connection with the InsGroup Lawsuit.
`
`REQUEST FOR PRODUCTION NO.2: Produce any drafts of the Settlement Agreement
`which wasentered into by You in connection with the InsGroup Lawsuit exchanged between You
`and any other party, or their counsel, in the InsGroup Lawsuit.
`
`REQUEST FOR PRODUCTION NO.3: Produce all Documents that were produced by You
`in response to any request for discovery propoundedin the InsGroup Lawsuit.
`
`REQUEST FOR PRODUCTION NO.4: Produce all Documents that were produced to You
`by any other party in response to any request for discovery propounded in the INSGROUP
`Lawsuit.
`
`REQUEST FOR PRODUCTION NO.5: Produce all Correspondence and Communications
`between You and Sutcliffe between June 1, 2019 and December 31, 2021 regarding orrelating to
`any of the Clients listed in the Sutcliffe Accounts, Your relationship with Sutcliffe, contracts or
`agreements with Sutcliffe, or any premiums, commissions, payments, or other consideration
`related to or arising out of any of the Clients listed in the Sutcliffe Accounts.
`
`REQUEST FOR PRODUCTION NO.6: Produce all Correspondence and Communications
`whether from and any of the Clients listed in the Sutcliffe Accounts between June 1, 2019 and
`December 31, 2021 related to moving the business from Underwood or attempting to obtain or
`accepting the insurance, financial services business, or risk managementservices of any nature of
`those Clients.
`
`premiums,
`reflecting
`all Documents
`REQUEST FOR PRODUCTION NO. 7: Produce
`commissions, payments, or other consideration received by You either directly or indirectly from
`any of the Clients listed in the Sutcliffe Accounts between January 1, 2020 and December31,
`2021.
`
`Page 7
`
`

`

`reflecting premiums,
`all Documents
`Produce
`REQUEST FOR PRODUCTION NO.8:
`commissions, payments, or other consideration provided to Sutcliffe between January 1, 2020 and
`December 31, 2021 related to any of the Clients listed in the Sutcliffe Accounts.
`
`Produce all Documents, Correspondence,
`REQUEST FOR PRODUCTION NO. 9:
`Communications with Pecan Deluxe Candy prior to May 28, 2020.
`
`Correspondence,
`Documents,
`REQUEST FOR PRODUCTION NO.10: All
`Communications related to a “Broker of record” letter concerning Pecan Deluxe Candy.
`
`Correspondence,
`Documents,
`REQUEST FOR PRODUCTION NO.11: All
`Communicationsrelated to a “Sutcliffe Account” letter concerning Pecan Deluxe Candy.
`
`all Documents, Correspondence,
`REQUEST FOR PRODUCTION NO.12: Produce
`Communications with Beltway Commercial Real Estate prior to February 4, 2020.
`
`all Documents, Correspondence,
`REQUEST FOR PRODUCTIONNO.13: Produce
`Communications between You and Maverick Capital, Ltd. before July 9, 2020.
`
`and
`
`and
`
`and
`
`and
`
`and
`
`and
`all Documents, Correspondence,
`REQUEST FOR PRODUCTION NO.14: Produce
`Communications between January 1, 2020 and December31, 2021 between You and each and any
`of the following:
`
`ONANWNYD
`
`Pecan Deluxe Candy;
`Maverick Capital, Ltd.;
`Chelsea Concepts, LLC;
`Beltway Commercial Real Estate;
`Exxir Development, LLC;
`Bishop Arts, LLC;
`Rex Construction;
`Visionary Fiber Technologies,Inc.
`9. Saskaway One LLC;
`10. Saskaway Two, LP;
`11. FP ITSC, LLC;
`12. WF Inwood Tavern, LLC
`13. Bruce & Margaret Nelson
`14. WE/TX Investments, LLC
`15. Connersville Commons, LLC;
`16. Johnathan and Kim Gallindo;
`17. Precise Hire, Inc.;
`18. Brand Capital Partners, LLC;
`19. BFI Saturen;
`20. Nguni Technologies, LLC;
`21. Edgeium,Inc.;
`22. 10 Clay Properties, LLC;
`23. WE Inwood Tavern LLC dba Inwood Tavern;
`
`Page 8
`
`

`

`24.
`25.
`26.
`27.
`28.
`
`ESL Teknologies, LLC;
`Brytar Inc dba Brytar Companies Corp,;
`Saskaway One, LLC;
`Exxir Treehaus, LLC;
`Any other Client listed on the Sutcliffe Accounts.
`
`and
`all Documents, Correspondence,
`REQUEST FOR PRODUCTION NO.15: Produce
`Communications between January 1, 2020 and December 31, 2021 between Sutcliffe and each and
`any of the following:
`
`RADARWN> Pecan Deluxe Candy;
`
`Maverick Capital, Ltd.;
`Chelsea Concepts, LLC;
`Beltway Commercial Real Estate;
`Exxir Development, LLC;
`Bishop Arts, LLC;
`Rex Construction;
`Visionary Fiber Technologies,Inc.
`Saskaway One LLC;
`. saskaway Two, LP;
`. FP TSC, LLC;
`. WF Inwood Tavern, LLC
`. Bruce & Margaret Nelson
`. WE/TX Investments, LLC
`. Connersville Commons, LLC;
`. Johnathan and Kim Gallindo;
`. Precise Hire, Inc.;
`. Brand Capital Partners, LLC;
`. BFI Saturen;
`. Nguni Technologies, LLC;
`. Edgeium, Inc.;
`. 10 Clay Properties, LLC;
`. WEF Inwood Tavern LLC dba Inwood Tavem;
`. ESL Teknologies, LLC;
`. Brytar Inc dba Brytar Companies Corp,;
`. Saskaway One, LLC;
`. Exxir Treehaus, LLC;
`. Any other Client listed on the Sutcliffe Accounts.
`
`reflecting premiums,
`all Documents
`REQUEST FOR PRODUCTION NO. 16: Produce
`commission, payments, or other consideration provided to Sutcliffe, whether directly or indirectly,
`between January 1, 2020 and December 31, 2021 related to or arising out of each and any of the
`following:
`
`1.
`
`Pecan Deluxe Candy;
`
`Page 9
`
`

`

`Maverick Capital, Ltd.;
`Chelsea Concepts, LLC;
`Beltway Commercial Real Estate;
`Exxir Development, LLC;
`Bishop Arts, LLC;
`Rex Construction;
`Visionary Fiber Technologies,Inc.
`Saskaway One LLC;
`. saskaway Two, LP;
`. FP TSC, LLC;
`. WE Inwood Tavern, LLC
`. Bruce & Margaret Nelson
`. WF/TX Investments, LLC
`. Connersville Commons, LLC;
`. Johnathan and Kim Gallindo;
`. Precise Hire, Inc.;
`. Brand Capital Partners, LLC;
`. BFI Saturen;
`. Nguni Technologies, LLC;
`. Edgeium,Inc.;
`. 10 Clay Properties, LLC;
`. WF Inwood Tavern LLC dba Inwood Tavern;
`. ESL Teknologies, LLC;
`. Brytar Inc dba Brytar Companies Corp,;
`. Saskaway One, LLC;
`. Exxir Treehaus, LLC;
`. Any other Client listed on the Sutcliffe Accounts.
`
`REQUEST FOR PRODUCTION NO. 17: Produce all Documents, Correspondence,
`Communications related to an appointment of You as Agent of Record for the following:
`
`and
`
`DAAMNEWN
`—i0RWN—Cc’
`
`Pecan Deluxe Candy;
`Maverick Capital, Ltd.
`Chelsea Concepts, LLC;
`Beltway Commercial Real Estate;
`Exxir Development, LLC;
`Bishop Arts, LLC;
`Rex Construction;
`Visionary Fiber Technologies,Inc.
`Saskaway One LLC;
`. Saskaway Two, LP;
`. FP TSC, LLC;
`. WEF Inwood Tavern, LLC
`. Bruce & Margaret Nelson
`. WE/TX Investments, LLC
`
`Page 10
`
`

`

`15.
`16.
`17.
`18.
`19.
`
`20.
`
`21.
`22.
`23.
`24.
`25.
`
`26.
`
`27.
`28.
`
`Connersville Commons, LLC;
`Johnathan and Kim Gallindo;
`Precise Hire, Inc.;
`Brand Capital Partners, LLC;
`BFI Saturen;
`Nguni Technologies, LLC;
`Edgeium,Inc.;
`10 Clay Properties, LLC;
`WEInwood Tavern LLC dba Inwood Tavem;
`ESL Teknologies, LLC;
`Brytar Inc dba Brytar Companies Corp,;
`Saskaway One, LLC;
`Exxir Treehaus, LLC;
`Anyother Client listed on the Sutcliffe Accounts.
`
`and
`all Documents, Correspondence,
`REQUEST FOR PRODUCTION NO.18: Produce
`Communications between You and Sutcliffe between January 1, 2020 and December 31, 2021
`pertaining to the following:
`
`SAANWNS
`
`9.
`10.
`
`11.
`
`12.
`13.
`14.
`15.
`16.
`
`17.
`
`18.
`19,
`20.
`21.
`22.
`
`23.
`
`24.
`25,
`26.
`27.
`
`Pecan Deluxe Candy;
`Maverick Capital, Ltd.;
`Chelsea Concepts, LLC;
`Beltway Commercial Real Estate;
`Exxir Development, LLC;
`Bishop Arts, LLC;
`Rex Construction;
`Visionary Fiber Technologies,Inc.
`Saskaway One LLC;
`Saskaway Two, LP;
`FP 11 SC, LLC;
`WFInwood Tavern, LLC
`Bruce & Margaret Nelson
`WE/TX Investments, LLC
`Connersville Commons, LLC;
`Johnathan and Kim Gallindo;
`Precise Hire, Inc.;
`Brand Capital Partners, LLC;
`BFI Saturen;
`Nguni Technologies, LLC;
`Edgeium,Inc.;
`10 Clay Properties, LLC;
`WE Inwood Tavern LLC dba Inwood Tavern;
`ESL Teknologies, LLC;
`Brytar Inc dba Brytar Companies Corp,;
`Saskaway One, LLC;
`Exxir Treehaus, LLC;
`
`Page 11
`
`

`

`28. Any other Client listed on the Sutcliffe Accounts.
`
`premiums,
`reflecting
`all Documents
`REQUEST FOR PRODUCTION NO.19: Produce
`commissions, payments, or other consideration received by You, whether directly or indirectly;
`between January 1, 2020 and December 31, 2021 pertaining to the following:
`
`
`
`PANAMAYWNHT
`
`Pecan Deluxe Candy;
`Maverick Capital, Ltd;
`Chelsea Concepts, LLC;
`Beltway Commercial Real Estate;
`Exxir Development, LLC;
`Bishop Arts, LLC;
`Rex Construction;
`Visionary Fiber Technologies,Inc.
`. Saskaway One LLC;
`10. Saskaway Two, LP;
`11. FP I SC, LLC;
`12. WF Inwood Tavern, LLC
`13. Bruce & Margaret Nelson
`14. WE/TX Investments, LLC
`15. Connersville Commons, LLC;
`16. Johnathan and Kim Gallindo;
`17. Precise Hire, Inc.;
`18. Brand Capital Partners, LLC;
`19. BFT Saturen;
`20. Nguni Technologies, LLC;
`21. Edgeium,Inc.;
`22. 10 Clay Properties, LLC;
`23. WF Inwood Tavern LLC dba Inwood Tavern;
`24. ESL Teknologies, LLC;
`25. Brytar Inc dba Brytar Companies Corp,;
`26. Saskaway One, LLC;
`27. Exxir Treehaus, LLC;
`28. Any other Client listed on the Sutcliffe Accounts.
`
`and
`Correspondence,
`Documents,
`REQUEST FOR PRODUCTION NO.20: All
`Communicationsrelating to any agreements, including but not limited to, agreements to indemnify
`You as it relates to any claims in the Lawsuit or pertaining to Sutcliffe.
`
`REQUEST FOR PRODUCTION NO.21: All
`Communications between You and Insgroup.
`
`Documents,
`
`Correspondence,
`
`and
`
`REQUEST FOR PRODUCTION NO.22: All contracts or agreements You and Sutcliffe
`entered into between June 15, 2019 and December31, 2023.
`
`Page 12
`
`

`

`and
`Correspondence,
`Documents,
`REQUEST FOR PRODUCTIONNO.23: All
`Communications related to any contracts or agreements You and Sutcliffe entered between June
`15, 2019 and December31, 2023.
`
`and
`Correspondence,
`Documents,
`REQUEST FOR PRODUCTION NO.24: All
`Communications related to any negotiations between You and Sutcliffe between June 15, 2019
`and December31, 2023.
`
`and
`Correspondence,
`Documents,
`REQUEST FOR PRODUCTION NO.25: All
`including all premiums,
`Communications related to Sutcliffe’s collection of any funds,
`commissions, and other consideration due in connection with all business produced or handled by
`Sutcliffe between January 1, 2020 and December 31, 2021.
`
`and
`Correspondence,
`Documents,
`REQUEST FOR PRODUCTIONNO.26: All
`Communications reflecting Sutcliffe’s remittance to You of any monies received in payment of
`premiumsonpolicies, or in payment of any other products or services for any of the Clients listed
`in the Sutcliffe Accounts between January 1, 2020 and December 31, 2021.
`
`and
`Correspondence,
`Documents,
`REQUEST FOR PRODUCTION NO.27: All
`Communications related to any compensation, commissions, payments, benefits of other
`remuneration received by Sutcliffe from You for the period January 1, 2020 through December
`31, 2021 related to any of the Clients listed in the Sutcliffe Accounts.
`
`REQUEST FOR PRODUCTION NO.28: All written statements relating to this Lawsuit.
`
`REQUEST FOR PRODUCTION NO.29: All written statements relating to the INSGROUP
`Lawsuit.
`
`and
`Communications,
`Documents,
`REQUEST FOR PRODUCTION NO.30: All
`Correspondence reflecting any account or policy provided for any of the Clie