Exhibit 3

Case 1:22-cv-23753-KMM Document 195-3 Entered on FLSD Docket 05/10/2023 Page 1 of 8
IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 22-CV-23753-MOORE/BECERRA 

EDWIN GARRISON, et al., on behalf of 

themselves and all other similarly situated, 

Plaintiffs, 

v. 

SAM BANKMAN-FRIED, et al., 

Defendants. 

 NOTICE OF OBJECTIONS TO NOTICE OF TAKING THE VIDEOTAPED 

DEPOSITION OF DEFENDANT GOLDEN STATE WARRIORS LLC’S RULE 30(b)(6) 

REPRESENTATIVE(S) 

Pursuant to Federal Rules of Civil Procedure 26, 30, and 32, Civil Local Rule 26.1, and 

the Discovery Procedures for Magistrate Judge Jacqueline Becerra, Defendant Golden State 

Warriors, LLC (“GSW”), by and through its undersigned attorneys, hereby objects to Plaintiffs’ 

Notice of Deposition of GSW pursuant to Federal Rule of Civil Procedure 30(b)(6), served on

May 2, 2023 (the “Notice”). 

GENERAL OBJECTIONS 

1. Plaintiffs’ deposition notice is premature, burdensome, and harassing, and GSW

expressly objects to the timing of the deposition. Plaintiffs have filed a motion seeking to 

consolidate this action with over a dozen others in a multi-district litigation. See In re: FTX 

Cryptocurrency Exchange Collapse Litig., MDL No. 3076. A consolidation as requested by 

Plaintiffs in their multi-district litigation petition necessarily would impact the scheduling and 

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scope of permissible discovery. It is harassing, burdensome, and unnecessary for Plaintiffs to 

seek GSW’s deposition while Plaintiffs simultaneously are seeking to fundamentally change the 

scope of this case and to potentially subject GSW to efforts by other plaintiffs in such a 

consolidated proceeding to demand another deposition of her. 

2. Plaintiffs have presented their notice of deposition as jurisdictional discovery.

The file name of the pdf that Plaintiffs sent to GSW is titled “20230421 – Notice of Taking 

Jurisdictional 30b6 Deposition of GSW.” Plaintiffs have filed a motion with Judge Moore 

seeking permission to take jurisdictional discovery that is still pending. Dkt. 163 (“Motion for 

Jurisdictional Discovery”). In that motion, Plaintiffs represented to Judge Moore that defendants 

including GSW have moved to dismiss for lack of personal jurisdiction based on “newly filed 

Sworn FTX Defendant Declarations, where they make new arguments to support an alleged lack 

of personal jurisdiction.” ECF No. 163 at 2. As to GSW, Plaintiffs’ representation to Judge 

Moore is false. GSW did not file any affidavit to support dismissal as to it. GSW makes a facial 

challenge to personal jurisdiction based on the allegations of Plaintiffs’ complaint. There is no 

factual dispute as to Plaintiffs’ jurisdictional allegations against GSW, and thus Plaintiffs have 

no basis to seek jurisdictional discovery from it. See In re Takata Airbag Prod. Liab. Litig., 396 

F. Supp. 3d 1101, 1157 (S.D. Fla. 2019) (denying jurisdictional discovery where there was “no

genuine factual dispute concerning personal jurisdiction because none of the parties submitted 

affidavit or declaration evidence in support of, or in opposition to, the exercise of personal 

jurisdiction”). 

3. To the extent Plaintiffs seek to depose GSW on the merits, as opposed to only for

“limited” jurisdictional discovery as Plaintiffs have requested in their pending Motion for 

Jurisdictional Discovery, the Notice is improper for additional reasons. Plaintiffs made no effort 

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to coordinate with GSW on a deposition date before unilaterally selecting May 8, 2023 and 

emailing GSW’s counsel the deposition notice. GSW objects that the proposed deposition is 

unduly burdensome and harassing as there is insufficient time for GSW to prepare a witness to 

speak on its behalf regarding the topics noticed by Plaintiffs. Given the number of parties alone, 

this case merits placement on the Court’s “Complex Track,” in which “discovery shall be 

completed within 270 to 365 days from the date of the Scheduling Order.” L.R. 16.1(a)(2)(C). 

That Scheduling Order has not even issued yet; there is no basis for Plaintiffs to depose GSW in 

less than a week. 

4. Plaintiffs only served this deposition notice on May 2, 2023 seeking to take

GSW’s deposition on May 8, 2023. Plaintiffs incorrectly contend that they served the deposition 

notice on April 28, 2023 (the date of the parties’ scheduling conference). Regardless of the date 

used, Plaintiffs’ deposition notice is defective because it failed to provide reasonable written 

notice of the deposition as required by Federal Rule of Civil Procedure 30(b)(1) and violates the 

rule that “a party desiring to take the deposition in another State of any person upon oral 

examination shall give at least fourteen (14) days’ notice in writing to every other party to the 

action and the deponent.” See L.R. 26.1(h). Further, because GSW received less than 14 days’ 

notice of the deposition, and GSW has objected and sought protection from the Notice in 

compliance with Civil Local Rule 26.1 and Judge Becerra’s Discovery Procedures, the proposed 

deposition could not be used against GSW pursuant to Federal Rule of Civil Procedure 

32(a)(5)(A). Requiring GSW to appear and give testimony at a deposition that cannot be used in 

the action is unduly burdensome and harassing. 

Case 1:22-cv-23753-KMM Document 195-3 Entered on FLSD Docket 05/10/2023 Page 4 of 8
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5. GSW objects to the location of the proposed deposition as unduly burdensome

and harassing. GSW is located in San Francisco, California, but the Notice purports to require 

GSW to be deposed in Los Angeles, California. 

SPECIFIC OBJECTIONS TO DEFINITIONS AND INSTRUCTIONS 

6. GSW specifically objects to the definitions of “GSW,” “You,” or “Your” as

overbroad and unduly burdensome because it includes not just GSW but also “any of its 

affiliates, subsidiaries, divisions, segments, predecessors, successors, officers, directors, 

employees, representatives, or agents.” GSW can only speak for itself and its employees in their 

capacity as employees. 

7. GSW specifically objects to the definition of “FTX Platform” as vague and

ambiguous because Plaintiffs provided two different definitions of this term. See Definition Nos. 

3 and 6. 

SPECIFIC OBJECTIONS AND RESPONSES 

TOPIC NO. 1: 

All Documents and responses provided in response to Plaintiffs’ request for production, 

each dated and served on April 21, 2023. 

RESPONSE 1: 

GSW restates and incorporates the General Objections and Specific Objections to 

Definitions and Instructions as though fully set forth in this response. GSW objects on the 

ground that this request is vague and unintelligible because GSW has not provided any 

documents or responses in response to Plaintiffs’ request for production dated April 21, 2023. 

This discovery was not served until April 28, 2023, and GSW’s deadline to respond and object to 

this discovery is May 29, 2023. Thus, it is impossible for GSW to testify on this topic on the 

proposed deposition date of May 8, 2023, which is several weeks before GSW’s responses and 

Case 1:22-cv-23753-KMM Document 195-3 Entered on FLSD Docket 05/10/2023 Page 5 of 8
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objections are due. GSW also objects to this request as it incorrectly contends that Plaintiffs 

served discovery on April 21, 2023. GSW objects to this request as overbroad to the extent it 

seeks information beyond the realm of “limited” jurisdictional discovery that Plaintiffs purport to 

seek through this deposition.

TOPIC NO. 2: 

All contracts or agreements and circumstances regarding Your “First-Of-Its-Kind” 

International Partnership with the FTX Entities. See https://www.nba.com/warriors/warriors-ftxpartnership-20211214 (accessed April 21, 2023). 

RESPONSE 2: 

GSW restates and incorporates the General Objections and Specific Objections to 

Definitions and Instructions as though fully set forth in this response. GSW objects to the phrase 

“circumstances” regarding GSW’s alleged “Partnership with the FTX Entities” as vague and 

unintelligible. GSW objects to this request as overbroad to the extent it seeks information 

beyond the realm of “limited” jurisdictional discovery that Plaintiffs purport to seek through this 

deposition. 

TOPIC NO. 3: 

All Documents and Communications, that show, evidence and/or relate to Defendant 

“targeting” Defendant’s Florida fans, and Florida’s FTX consumers, including but not limited to 

(1) any advertising for the FTX Platform or FTX Entities located in the Chase Center that was

broadcast in or viewable by Florida investors and GSW fans residing in Florida during GSW 

games (including GSW home games where GSW played either the Miami Heat or Orlando 

Magic); (2) any advertising for the FTX Platform or FTX Entities located in the Warriors 

Case 1:22-cv-23753-KMM Document 195-3 Entered on FLSD Docket 05/10/2023 Page 6 of 8
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Gaming Squad court during NBA 2K League games; and (3) any NFTs that GSW offered for 

sale on the FTX Platform. 

RESPONSE 3: 

GSW restates and incorporates the General Objections and Specific Objections to 

Definitions and Instructions as though fully set forth in this response. GSW objects to this 

request as overbroad and unduly burdensome because no witness can be knowledgeable of “All 

Documents and Communications” as referred to in this request. GSW also objects to this request 

as it calls for a legal conclusion that GSW “targeted” Florida fans. GSW objects to this request 

as overbroad to the extent it seeks information beyond the realm of “limited” jurisdictional 

discovery that Plaintiffs purport to seek through this deposition, and in particular information 

about “advertising for the FTX Platform or FTX Entities located in the Warriors Gaming Squad 

court during NBA 2K League games” and “NFTs that GSW offered for sale on the FTX 

Platform” because there is no relationship with Florida on the face of these topics. 

TOPIC NO. 4: 

All research or due diligence YOU and/or the NBA performed about the FTX Entities, 

the FTX Platform, or whether YBAs or FTT constitute a security under any federal or state law. 

RESPONSE 4: 

GSW restates and incorporates the General Objections and Specific Objections to 

Definitions and Instructions as though fully set forth in this response. GSW objects to this 

request as overbroad because it seeks information beyond the realm of “limited” jurisdictional 

discovery that Plaintiffs purport to seek through this deposition. GSW also objects to this 

request as seeking information beyond GSW’s possession, custody, and/or control because it 

asks for “research or due diligence . . . the NBA performed.” GSW also objects to this request to 

Case 1:22-cv-23753-KMM Document 195-3 Entered on FLSD Docket 05/10/2023 Page 7 of 8
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the extent it seeks information protected by the attorney client privilege or attorney work product 

protection regarding “whether YBAs or FTT constitute a security under any federal or state law.” 

Dated: May 3, 2023 Respectfully submitted, 

COLSON, HICKS, EIDSON, P.A. 

255 Alhambra Circle, Penthouse 

Coral Gables, Florida 33134 

(305) 476-7400

By: /s/ Roberto Martínez 

Roberto Martínez 

Florida Bar No. 305596 

 bob@colson.com 

Stephanie A. Casey 

Florida Bar No. 97483 

 scasey@colson.com 

Zachary Lipshultz 

Florida Bar No. 123594 

 zach@colson.com 

GIBSON, DUNN & CRUTCHER LLP 

555 Mission Street, Suite 3000 

San Francisco, CA 94105-0921 

Phone: 415.393.8379 

By: /s/ Matthew S. Kahn 

Matthew S. Kahn (pro hac vice) 

 MKahn@gibsondunn.com 

Michael J. Kahn (pro hac vice) 

 MJKahn@gibsondunn.com

Jamila MacEbong (pro hac vice) 

 JMacEbong@gibsondunn.com 

333 South Grand Avenue 

Suite 4600 

Los Angeles, CA 90071-3197 

Phone: 213.229.7155 

Attorneys for Defendant Golden State Warriors, 

LLC

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