Exhibit 1 

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UNITED STATES DISTRICT COURT FOR THE 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 2:20-CV-14159-ROSENBERG/MAYNARD 

DJ LINCOLN ENTERPRISES, INC. ) 

 ) 

 Plaintiff, ) 

 ) 

v. ) 

 ) 

 ) 

GOOGLE, LLC ) 

 ) 

 Defendant. ) 

 ) 

PLAINTIFF’S INTERROGATORIES AND 

REQUEST FOR PRODUCTION OF DOCUMENTS 

Plaintiff, DJ Lincoln Enterprises, Inc. (“Plaintiff”), by counsel, pursuant to Rules 

26, 33 and 34 of the Federal Rules of Civil Procedure (the “Rules”), hereby requests that 

defendant, Google, LLC (”Defendant”), answer the following interrogatories, separately 

in writing and under oath, and produce the following documents for inspection and 

copying at the law office of John C. Smith, Esquire, John C. Smith, P.A., 2385 NW 

Executive Center Drive, Suite 100, Boca Raton, FL 33431 or at another location or by 

another method agreed to by the parties, within the time prescribed by the Rules: 

Continued On Next Page 

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DEFINITIONS AND INSTRUCTIONS 

 1. The term “document” shall mean and include all written and graphic 

matter of every kind and description, whether written or produced or transmitted by 

computer, typewriter, printer, photocopier or other machine or by hand, whether in 

printed form or on computer disk, and whether in the actual or constructive possession, 

custody or control of you, including, without limitation, any and all files, records, disks, 

emails, text messages, instant messages, iMessages, direct messages, letters, 

correspondence, memoranda, notes, statements, transcripts, workpapers, sound 

recordings, cds, dvds, videotapes, charts, reports, books, ledgers, registers, books of 

account, account statements, financial statements, checks, check stubs, deposit receipts, 

and any other written or graphic record of any kind, whether or not such documents are 

claimed to be privileged from discovery on any ground. 

 2. “You” and “your” shall mean the person or entity to whom/which this 

request or subpoena is directed, including his, her, their or its agents, representatives, 

employees, attorneys, experts, investigators, insurers or anyone acting on behalf of the 

foregoing. 

 3. “Person” or “person” means any individual, sole proprietorship, 

partnership (general or limited), limited liability company, limited liability partnership, 

corporation, association, trust or other entity. 

 4. “Relating to” means to refer to, reflect, pertain to, or in any manner be 

connected with the matter discussed. 

 5. “Plaintiff” means Plaintiff, DJ Lincoln Enterprises, Inc., including any 

agent, representative or employee of Plaintiff. 

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 6. “Defendant” means Defendant, Google, LLC, including any employee, 

independent contractor, engineer, officer, director, representative, or agent of the 

Defendant. 

 7. “Identify” or “identification”, when used in reference to a person, means 

to state their full name, their present or last known home and business addressees) and 

their present or last known home and business telephone number(s). “Identify” or 

“identification”, when used in reference to a document, means to state or specify the type 

of document, e.g. letter, memoranda, etc., its date, its author, signer, addressee, its 

contents, and any other information necessary to identify the document for purposes of an 

interrogatory, request for production of documents or subpoena duces tecum. As an 

alternative to identifying the document, a copy may be attached to your answer. If any 

such document was but is no longer in your possession or subject to your control, state 

what happened to the document. “Identify” or “identification”, when used in reference to 

a communication, representation or discussion, means to state the person(s) to whom 

such communication was made, the medium of communication, e.g., letter, telephone, 

fax, email, etc., the date of such communication, and the subject matter and substance of 

such communication. 

 8. “Describe” means state what is requested to be described, including all 

facts and opinions known and held regarding what is requested to be described, and (I) 

the identity of each person involved or having knowledge of each fact or opinion relating 

to what is described, (II) the identity of each document evidencing the answer given or 

relating to what is disclosed in the answer given, and (III) all relevant or material dates or 

time periods. 

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 9. If you consider any document called for by a request for production of 

documents to be privileged from discovery, include in your answer/response a list of the 

documents withheld, identifying each document by date, author, addressee, all recipients, 

all persons who have seen the document, the title and a brief description of the subject 

matter which will allow for a determination whether the document is privileged. Finally, 

you should state the grounds upon which each document is claimed to be privileged. 

 10. The definitions used in the Plaintiff’s Amended Complaint filed in this 

action [ECF No. 19] are restated and incorporated herein by reference. To the extent of 

any inconsistency, the definitions in the Amended Complaint control. 

Continued on Next Page 

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INTERROGATORIES 

 Plaintiff propounds the following interrogatories upon Defendant, to be answered 

separately, in writing, and under oath: 

 1. Identify all algorithms, systems and/or programs created by Defendant that 

were/are intended to rank, re-rank, index, de-index, classify, manipulate, favor, penalize, 

restrict, limit, promote, improve or otherwise alter or affect the position of a webpage or 

website on Defendant’s search engine results page. 

ANSWER: 

 2. Identify all written policies, practices, methods, procedures and guidelines 

published by Defendant, internally or otherwise, between 2010 and 2020 that discuss how 

Defendant finds, indexes, evaluates, and/or ranks websites. 

ANSWER: 

 3. Identify all documents, including reports and emails, published by 

Defendant, internally or otherwise, between 2010 and 2020 that mention or discuss 

“black lists”, blacklisting of websites, or that discuss the suppression, filtering, 

classification or categorization of websites, including the application of value judgments 

or opinions like as “unsafe” and “inappropriate”. 

ANSWER: 

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 4. Identify all documents, including reports and emails, published by 

Defendant, internally or otherwise, between 2010 and 2020 that mention or discuss the 

imposition of penalties by Defendant against websites. 

ANSWER: 

 5. Identify all Search Quality Raters employed or engaged by Defendant 

between 2010 and 2020, and all employees or agents of Defendant who manually 

intervened in Search results. 

ANSWER: 

 6. Identify all articles or blogs published by Defendant and all consoles, help 

communities/centers or chatrooms in which any agent of Defendant, human or otherwise, 

offered advice between 2010 and 2020 concerning search engine optimization, how to 

increase the quantity and quality of traffic to a website, and/or the improvement of Search 

results. 

ANSWER: 

 7. Identify all sitemaps provided to Defendant by Plaintiff between 2010 and 

2020. 

ANSWER: 

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 8. Identify all information about Plaintiff’s websites 

www.SeniorLivingNation,com and https://SeniorCare.care contained in Defendant’s 

Search index, including, without limitation, the results of daily and/or monthly crawls 

and indexing between 2010 and 2020. 

ANSWER: 

 9. Describe in detail and identify ALL communications between Plaintiff and 

Defendant, including, without limitation, the substance of all chats, between 2010 and 

May 20, 2020. For EACH such statement, identify: 

 a. Where and/or how such communications occurred, i.e., in person, 

 by telephone, by mail, by email, by text message, or via an Internet chat; 

 b. the date(s) of ALL communications; 

 c. The identity of all participants; 

 d. The exact words and/or entire substance of ALL statements made 

 by Defendant to Plaintiff; and 

 e. PRODUCE all documents that constitute, memorialize, evidence, 

 demonstrate, show or refer to such communications, including all emails, text 

 messages, notes, memoranda, correspondence, transcripts, records of 

 conversations, screenshots, posts, and other records. 

THERE WILL BE AN OBJECTION RAISED TO ANY FACT NOT 

DISCLOSED IN RESPONSE TO THIS INTERROGATORY.

ANSWER: 

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REQUEST FOR PRODUCTION OF DOCUMENTS 

 Plaintiff requests Defendant to produce complete and genuine copies of the 

following: 

 UNLESS OTHERWISE NOTED, THE FOLLOWING REQUEST FOR 

PRODUCTION OF DOCUMENTS SEEKS DOCUMENTS AND 

ELECTRONICALLY STORED INFORMATION FOR THE TIME PERIOD 

BETWEEN MAY 20, 2010 AND MAY 20, 2020, INCLUSIVE (the “RELEVANT 

PERIOD”) 

 IF DEFENDANT HAS NO DOCUMENTS RESPONSIVE TO THE 

FOLLOWING REQUESTS, THE ANSWER SHOULD CLEARLY STATE 

“NONE” OR “NO DOCUMENTS”.

 1. All documents identified in Defendant’s answers to the above 

Interrogatories and/or requested in or by the above Interrogatories. 

 2. All documents that constitute, evidence or reflect communications 

between Plaintiff and Defendant. 

THESE REQUESTS ARE CONTINUING IN NATURE AS PROVIDED 

FOR IN THE RULES. 

 PLAINTIFF HEREBY REQUESTS THAT DEFENDANT SUPPLEMENT 

ITS DISCOVERY RESPONSES IMMEDIATELY UPON RECEIPT OF 

ADDITIONAL DOCUMENTS AND INFORMATION. 

DATED: October 26, 2020 

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 DJ LINCOLN ENTERPRISES, INC. 

 By: /s/ John C. Smith 

 John C. Smith, Esquire 

 John C. Smith, P.A. 

 2385 NW Executive Center Drive, Suite 100 

 Boca Raton, FL 33431 

 561-394-4666 Voice 

 561-962-2710 Fax 

 jsmith@bocaiplaw.com

www.boaciplaw.com

 Counsel for the Plaintiff

 Steven S. Biss (VSB # 32972) 

 300 West Main Street, Suite 102 

 Charlottesville, Virginia 22903 

 Telephone: (804) 501-8272 

 Facsimile: (202) 318-4098 

 Email: stevenbiss@earthlink.net

 Counsel for the Plaintiff 

 (Application for Admission Pro Hac Vice 

 To be Filed)

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CERTIFICATE OF SERVICE 

 I hereby certify that on October 26, 2020 the foregoing was served on counsel for 

the Defendants electronically in PDF. 

 By: /s/ John C. Smith 

 John C. Smith, Esquire 

 John C. Smith, P.A. 

 2385 NW Executive Center Drive, Suite 100 

 Boca Raton, FL 33431 

 561-394-4666 Voice 

 561-962-2710 Fax 

 jsmith@bocaiplaw.com

www.boaciplaw.com

 Counsel for the Plaintiff

 Steven S. Biss (VSB # 32972) 

 300 West Main Street, Suite 102 

 Charlottesville, Virginia 22903 

 Telephone: (804) 501-8272 

 Facsimile: (202) 318-4098 

 Email: stevenbiss@earthlink.net

 Counsel for the Plaintiff 

 (Application for Admission Pro Hac Vice 

 To be Filed)

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