Composite Exhibit A

Case 1:22-cv-23753-KMM Document 162-1 Entered on FLSD Docket 04/26/2023 Page 1 of 50
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-cv-23753-KMM 

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

 

SAM BANKMAN-FRIED, et al., 

Defendants. 

/

PLAINTIFF’S FIRST SET OF THREE REQUESTS FOR PRODUCTION TO 

DEFENDANT STEPHEN CURRY 

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, Stephen Curry 

(“Curry”), produce the documents requested in response to these three requests. 

Dated: April 21, 2023 Respectfully submitted, 

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Florida Bar No. 984280 

adam@moskowitz-law.com 

Joseph M. Kaye 

Florida Bar No. 117520 

joseph@moskowitz-law.com 

THE MOSKOWITZ LAW FIRM, PLLC 

2 Alhambra Plaza, Suite 601 

Coral Gables, FL 33134 

Telephone: (305) 740-1423 

By: /s/ David Boies 

David Boies 

(Pro Hac Vice) 

Alex Boies 

(Pro Hac Vice) 

BOIES SCHILLER FLEXNER LLP 

333 Main Street 

Armonk, NY 10504 

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Phone: (914) 749–8200 

dboies@bsfllp.com 

By: /s/ Stephen Neal Zack 

Stephen Neal Zack 

Florida Bar No. 145215 

BOIES SCHILLER FLEXNER LLP 

100 SE 2nd St., Suite 2800 

Miami, FL 33131 

Office: 305-539-8400 

szack@bsfllp.com 

Co-Counsel for Plaintiff and the Class 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that on April 21, 2023, a true and correct copy of the foregoing was 

sent via electronic mail to counsel for Defendants. 

 By: /s/ Adam M. Moskowitz______ 

 ADAM M. MOSKOWITZ 

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DEFINITIONS AND INSTRUCTIONS 

Unless otherwise specified, the terms set forth below have the following meanings: 

1. “Curry,” “You,” or “Your” means Defendant Stephen Curry and any of his 

affiliates, representatives, or agents. 

2. “FTX Entities” means West Realm Shires Services, Inc., FTX Trading Ltd, 

Blockfolio, Inc., and any of their affiliates, subsidiaries, divisions, segments, predecessors, 

successors, officers, directors, employees, representatives, or agents. 

3. “FTX Platform” refers to the FTX Entities’ mobile application and/or web-based 

cryptocurrency investment service that places cryptocurrency trade orders on behalf of users. 

4. “YBAs” refers to the Yield-Bearing Accounts offered by the FTX Entities on the 

FTX Platform. 

5. “FTT” refers to the native cryptocurrency exchange token of the FTX Platform 

ecosystem. 

6. “FTX Platform” refers to the FTX Entities’ mobile application cryptocurrency 

investment service that places cryptocurrency trade orders on behalf of users. 

7. “Document(s)” means any written, printed, typed or other graphic matter, of any 

kind or nature, whether in hard copy or electronic format, whether the original, draft, or a copy 

and copies bearing notations or marks not found on the original, including but not limited to 

memoranda, reports, recommendations, notes, letters, envelopes, post-its, emails, telegrams, 

messages, manuscripts, studies, analyses, tests, comparisons, books, articles, pamphlets, 

magazines, newspapers, booklets, circulars, bulletins, notices, instructions, minutes, 

agreements, contracts, and all other written communications, of any type, including inter and 

intra-office communications, purchase orders, invoices, bills, receipts, questionnaires, surveys, 

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charts, graphs, videos, photographs, sketches, drawings, house sheets, tapes, voice messages or 

other recordings, print-outs or compilations from which information can be obtained or, if 

necessary, translated through detection devices into reasonably usable form, including all 

underlying or preparatory materials and drafts thereof. 

8. Unless otherwise stated in a request, the time period for which you must respond 

is beginning in January 1, 2019 and ending at the present time. 

9. “Person” or “People” means any natural person(s) or any business, legal, or 

governmental entity (or entities) or association(s). 

10. All/Each – The terms “all” and “each” shall be construed as meaning either all 

or each as necessary to bring within the scope of the discovery request all responses that might 

otherwise be construed to be outside its scope. 

11. Objections: Where an objection is made to any request, the objection shall state 

with specificity all grounds. Any ground not stated in an objection within the time provided by 

the Federal Rules of Civil Procedure, or by the Court’s order, or any extensions thereof, shall be 

waived. 

12. Whenever a reference to a business entity appears, the reference shall mean the 

business entity, its affiliated companies, partnerships, divisions, subdivisions, directors, officers, 

employees, agents, clients or other representatives of affiliated third parties. 

INSTRUCTIONS 

1. Production of documents and items requested herein shall be made at the offices of The 

Moskowitz Law Firm, P.O. Box 141609, Coral Gables, FL 33114, or for hand deliveries 

at 251 Valencia Ave #141609, Coral Gables, FL 33114, or via electronic mail to the email 

addresses provided in the signature blocks of the attorneys serving these requests. 

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2. These requests shall include all documents that are in the possession, custody or control of 

Defendant or in the possession, custody or control of the present or former agents, 

representatives, or attorneys of Defendant, or any and all persons acting on the behalf of 

Defendant, or its present or former agents, representatives, or attorneys. 

3. For any document covered by a request that is withheld from production, Defendant shall 

provide the following information in the form of a privilege log: 

a. the reasons and facts supporting any withholding; 

b. the date such document was prepared; 

c. the names, employment positions and addresses of the author or 

preparers of such document; 

d. the names, employment positions, and the addresses of each person 

who received such document; 

e. the title and a brief description of the document; and 

f. the number of the request under which such document would be 

produced but for the objection. 

4. If any document responsive to a request has been destroyed, produce all documents 

describing or referencing: 

a. the contents of the lost or destroyed document; 

b. all locations in which any copy of the lost or destroyed document 

had been maintained; 

c. the date of such loss or destruction; 

d. the name of each person who ordered, authorized, and carried out 

the destruction of any responsive document; 

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e. all document retention and destruction policies in effect at the time 

any requested document was destroyed; and 

f. all efforts made to locate any responsive document alleged to have 

been lost. 

5. In producing the documents requested, indicate the specific request(s) pursuant to which 

document or group of documents is being produced. 

6. These requests should be deemed continuing, and supplemental productions should be 

provided as additional documents become available. 

7. All documents are to be produced in the following method: 

a) Single page .TIFF 

b) Color .jpg (Documents wherein reflection of importance relies on color, shall be 

produced in .jpg format) 

c) OCR at document level (All documents are to be provided with searchable text files 

with the exception of the redacted portions of redacted documents) 

d) Electronic documents and Emails are to be processed and converted from the 

electronic format to single page tiff 

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THREE REQUESTS FOR PRODUCTION 

Please refer to the Definitions and Instructions when responding to these requests. To the 

extent that any of these requests seek information considered by Defendants to be 

confidential, Plaintiff have already agreed to enter into any reasonable confidentiality 

agreement with Defendants to protect such alleged confidential information. 

1. All Documents and Communications, including contracts or agreements, 

regarding Your Global Partnership with the FTX Entities. See 

https://www.prnewswire.com/news-releases/nba-superstar-stephen-curry-becomes-globalambassador-and-shareholder-of-leading-cryptocurrency-exchange-ftx-through-long-termpartnership-301370497.html (accessed April 21, 2023). 

2. All Documents and Communications, including but not limited to Contracts or 

Agreements and any negotiations, that shows, evidences and/or relates to Defendant “targeting” 

Defendant’s Florida fans, and Florida’s FTX consumers, including but not limited to, through 

any NFTs You offered for sale on the FTX Platform, or through the extremely well-marketed 

the “#notanexpert” campaign and Your statements made in that campaign, including “I’m not 

an expert, and I don’t need to be. With FTX I have everything I need to buy, sell, and trade 

crypto safely.” See https://www.youtube.com/watch?v=gsy2N-XI04o (accessed April 21, 

2023); see also https://www.prnewswire.com/news-releases/stephen-curry-drops-surprise-nftfor-charity-to-commemorate-breaking-all-time-nba-three-point-record-301447687.html

(accessed April 21, 2023). 

3. All documents regarding any and all communications with the FTX Entities 

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

Case 1:22-cv-23753-KMM Document 162-1 Entered on FLSD Docket 04/26/2023 Page 8 of 50
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-cv-23753-KMM 

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

 

SAM BANKMAN-FRIED, et al., 

Defendants. 

/

PLAINTIFF’S FIRST SET OF THREE REQUESTS FOR PRODUCTION TO 

DEFENDANT LAWRENCE GENE DAVID 

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, Lawrence Gene 

David (“David”), produce the documents requested in response to these three requests. 

Dated: April 21, 2023 Respectfully submitted, 

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Florida Bar No. 984280 

adam@moskowitz-law.com 

Joseph M. Kaye 

Florida Bar No. 117520 

joseph@moskowitz-law.com 

THE MOSKOWITZ LAW FIRM, PLLC 

2 Alhambra Plaza, Suite 601 

Coral Gables, FL 33134 

Telephone: (305) 740-1423 

By: /s/ David Boies 

David Boies 

(Pro Hac Vice) 

Alex Boies 

(Pro Hac Vice) 

BOIES SCHILLER FLEXNER LLP 

333 Main Street 

Armonk, NY 10504 

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Phone: (914) 749–8200 

dboies@bsfllp.com 

By: /s/ Stephen Neal Zack 

Stephen Neal Zack 

Florida Bar No. 145215 

BOIES SCHILLER FLEXNER LLP 

100 SE 2nd St., Suite 2800 

Miami, FL 33131 

Office: 305-539-8400 

szack@bsfllp.com 

Co-Counsel for Plaintiff and the Class 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that on April 21, 2023, a true and correct copy of the foregoing was 

sent via electronic mail to counsel for Defendants. 

 By: /s/ Adam M. Moskowitz______ 

 ADAM M. MOSKOWITZ 

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DEFINITIONS AND INSTRUCTIONS 

Unless otherwise specified, the terms set forth below have the following meanings: 

1. “David,” “You,” or “Your” means Defendant Lawrence Gene David and any of 

his affiliates, representatives, or agents. 

2. “FTX Entities” means West Realm Shires Services, Inc., FTX Trading Ltd, 

Blockfolio, Inc., and any of their affiliates, subsidiaries, divisions, segments, predecessors, 

successors, officers, directors, employees, representatives, or agents. 

3. “FTX Platform” refers to the FTX Entities’ mobile application and/or web-based 

cryptocurrency investment service that places cryptocurrency trade orders on behalf of users. 

4. “YBAs” refers to the Yield-Bearing Accounts offered by the FTX Entities on the 

FTX Platform. 

5. “FTT” refers to the native cryptocurrency exchange token of the FTX Platform 

ecosystem. 

6. “FTX Platform” refers to the FTX Entities’ mobile application cryptocurrency 

investment service that places cryptocurrency trade orders on behalf of users. 

7. “Document(s)” means any written, printed, typed or other graphic matter, of any 

kind or nature, whether in hard copy or electronic format, whether the original, draft, or a copy 

and copies bearing notations or marks not found on the original, including but not limited to 

memoranda, reports, recommendations, notes, letters, envelopes, post-its, emails, telegrams, 

messages, manuscripts, studies, analyses, tests, comparisons, books, articles, pamphlets, 

magazines, newspapers, booklets, circulars, bulletins, notices, instructions, minutes, 

agreements, contracts, and all other written communications, of any type, including inter and 

intra-office communications, purchase orders, invoices, bills, receipts, questionnaires, surveys, 

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charts, graphs, videos, photographs, sketches, drawings, house sheets, tapes, voice messages or 

other recordings, print-outs or compilations from which information can be obtained or, if 

necessary, translated through detection devices into reasonably usable form, including all 

underlying or preparatory materials and drafts thereof. 

8. Unless otherwise stated in a request, the time period for which you must respond 

is beginning in January 1, 2019 and ending at the present time. 

9. “Person” or “People” means any natural person(s) or any business, legal, or 

governmental entity (or entities) or association(s). 

10. All/Each – The terms “all” and “each” shall be construed as meaning either all 

or each as necessary to bring within the scope of the discovery request all responses that might 

otherwise be construed to be outside its scope. 

11. Objections: Where an objection is made to any request, the objection shall state 

with specificity all grounds. Any ground not stated in an objection within the time provided by 

the Federal Rules of Civil Procedure, or by the Court’s order, or any extensions thereof, shall be 

waived. 

12. Whenever a reference to a business entity appears, the reference shall mean the 

business entity, its affiliated companies, partnerships, divisions, subdivisions, directors, officers, 

employees, agents, clients or other representatives of affiliated third parties. 

INSTRUCTIONS 

1. Production of documents and items requested herein shall be made at the offices of The 

Moskowitz Law Firm, P.O. Box 141609, Coral Gables, FL 33114, or for hand deliveries 

at 251 Valencia Ave #141609, Coral Gables, FL 33114, or via electronic mail to the email 

addresses provided in the signature blocks of the attorneys serving these requests. 

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2. These requests shall include all documents that are in the possession, custody or control of 

Defendant or in the possession, custody or control of the present or former agents, 

representatives, or attorneys of Defendant, or any and all persons acting on the behalf of 

Defendant, or its present or former agents, representatives, or attorneys. 

3. For any document covered by a request that is withheld from production, Defendant shall 

provide the following information in the form of a privilege log: 

a. the reasons and facts supporting any withholding; 

b. the date such document was prepared; 

c. the names, employment positions and addresses of the author or 

preparers of such document; 

d. the names, employment positions, and the addresses of each person 

who received such document; 

e. the title and a brief description of the document; and 

f. the number of the request under which such document would be 

produced but for the objection. 

4. If any document responsive to a request has been destroyed, produce all documents 

describing or referencing: 

a. the contents of the lost or destroyed document; 

b. all locations in which any copy of the lost or destroyed document 

had been maintained; 

c. the date of such loss or destruction; 

d. the name of each person who ordered, authorized, and carried out 

the destruction of any responsive document; 

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e. all document retention and destruction policies in effect at the time 

any requested document was destroyed; and 

f. all efforts made to locate any responsive document alleged to have 

been lost. 

5. In producing the documents requested, indicate the specific request(s) pursuant to which 

document or group of documents is being produced. 

6. These requests should be deemed continuing, and supplemental productions should be 

provided as additional documents become available. 

7. All documents are to be produced in the following method: 

a) Single page .TIFF 

b) Color .jpg (Documents wherein reflection of importance relies on color, shall be 

produced in .jpg format) 

c) OCR at document level (All documents are to be provided with searchable text files 

with the exception of the redacted portions of redacted documents) 

d) Electronic documents and Emails are to be processed and converted from the 

electronic format to single page tiff 

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THREE REQUESTS FOR PRODUCTION 

Please refer to the Definitions and Instructions when responding to these requests. To the 

extent that any of these requests seek information considered by Defendants to be 

confidential, Plaintiff have already agreed to enter into any reasonable confidentiality 

agreement with Defendants to protect such alleged confidential information. 

1. All Documents and Communications, including contracts or agreements, 

regarding any business You conducted with the FTX Entities. 

2. 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 the “Don’t Miss Out on Crypto” 2022 Super Bowl advertisement. See 

https://youtu.be/hWMnbJJpeZc (accessed April 21, 2023). 

3. All documents regarding any and all communications with the FTX Entities 

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

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-cv-23753-KMM 

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

 

SAM BANKMAN-FRIED, et al., 

Defendants. 

/

PLAINTIFF’S FIRST SET OF THREE REQUESTS FOR PRODUCTION TO 

DEFENDANT GOLDEN STATE WARRIORS LLC 

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, Golden State 

Warriors LLC (“GSW”), produce the documents requested in response to these three requests. 

Dated: April 21, 2023 Respectfully submitted, 

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Florida Bar No. 984280 

adam@moskowitz-law.com 

Joseph M. Kaye 

Florida Bar No. 117520 

joseph@moskowitz-law.com 

THE MOSKOWITZ LAW FIRM, PLLC 

2 Alhambra Plaza, Suite 601 

Coral Gables, FL 33134 

Telephone: (305) 740-1423 

By: /s/ David Boies 

David Boies 

(Pro Hac Vice) 

Alex Boies 

(Pro Hac Vice) 

BOIES SCHILLER FLEXNER LLP 

333 Main Street 

Armonk, NY 10504 

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Phone: (914) 749–8200 

dboies@bsfllp.com 

By: /s/ Stephen Neal Zack 

Stephen Neal Zack 

Florida Bar No. 145215 

BOIES SCHILLER FLEXNER LLP 

100 SE 2nd St., Suite 2800 

Miami, FL 33131 

Office: 305-539-8400 

szack@bsfllp.com 

Co-Counsel for Plaintiff and the Class 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that on April 21, 2023, a true and correct copy of the foregoing was 

sent via electronic mail to counsel for Defendants. 

 By: /s/ Adam M. Moskowitz______ 

 ADAM M. MOSKOWITZ 

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DEFINITIONS AND INSTRUCTIONS 

Unless otherwise specified, the terms set forth below have the following meanings: 

1. “GSW,” “You,” or “Your” means Defendant Golden State Warriors LLC and 

any of its affiliates, subsidiaries, divisions, segments, predecessors, successors, officers, 

directors, employees, representatives, or agents. 

2. “FTX Entities” means West Realm Shires Services, Inc., FTX Trading Ltd, 

Blockfolio, Inc., and any of their affiliates, subsidiaries, divisions, segments, predecessors, 

successors, officers, directors, employees, representatives, or agents. 

3. “FTX Platform” refers to the FTX Entities’ mobile application and/or web-based 

cryptocurrency investment service that places cryptocurrency trade orders on behalf of users. 

4. “YBAs” refers to the Yield-Bearing Accounts offered by the FTX Entities on the 

FTX Platform. 

5. “FTT” refers to the native cryptocurrency exchange token of the FTX Platform 

ecosystem. 

6. “FTX Platform” refers to the FTX Entities’ mobile application cryptocurrency 

investment service that places cryptocurrency trade orders on behalf of users. 

7. “Document(s)” means any written, printed, typed or other graphic matter, of any 

kind or nature, whether in hard copy or electronic format, whether the original, draft, or a copy 

and copies bearing notations or marks not found on the original, including but not limited to 

memoranda, reports, recommendations, notes, letters, envelopes, post-its, emails, telegrams, 

messages, manuscripts, studies, analyses, tests, comparisons, books, articles, pamphlets, 

magazines, newspapers, booklets, circulars, bulletins, notices, instructions, minutes, 

agreements, contracts, and all other written communications, of any type, including inter and 

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intra-office communications, purchase orders, invoices, bills, receipts, questionnaires, surveys, 

charts, graphs, videos, photographs, sketches, drawings, house sheets, tapes, voice messages or 

other recordings, print-outs or compilations from which information can be obtained or, if 

necessary, translated through detection devices into reasonably usable form, including all 

underlying or preparatory materials and drafts thereof. 

8. Unless otherwise stated in a request, the time period for which you must respond 

is beginning in January 1, 2019 and ending at the present time. 

9. “Person” or “People” means any natural person(s) or any business, legal, or 

governmental entity (or entities) or association(s). 

10. All/Each – The terms “all” and “each” shall be construed as meaning either all 

or each as necessary to bring within the scope of the discovery request all responses that might 

otherwise be construed to be outside its scope. 

11. Objections: Where an objection is made to any request, the objection shall state 

with specificity all grounds. Any ground not stated in an objection within the time provided by 

the Federal Rules of Civil Procedure, or by the Court’s order, or any extensions thereof, shall be 

waived. 

12. Whenever a reference to a business entity appears, the reference shall mean the 

business entity, its affiliated companies, partnerships, divisions, subdivisions, directors, officers, 

employees, agents, clients or other representatives of affiliated third parties. 

INSTRUCTIONS 

1. Production of documents and items requested herein shall be made at the offices of The 

Moskowitz Law Firm, P.O. Box 141609, Coral Gables, FL 33114, or for hand deliveries 

at 251 Valencia Ave #141609, Coral Gables, FL 33114, or via electronic mail to the email 

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addresses provided in the signature blocks of the attorneys serving these requests. 

2. These requests shall include all documents that are in the possession, custody or control of 

Defendant or in the possession, custody or control of the present or former agents, 

representatives, or attorneys of Defendant, or any and all persons acting on the behalf of 

Defendant, or its present or former agents, representatives, or attorneys. 

3. For any document covered by a request that is withheld from production, Defendant shall 

provide the following information in the form of a privilege log: 

a. the reasons and facts supporting any withholding; 

b. the date such document was prepared; 

c. the names, employment positions and addresses of the author or 

preparers of such document; 

d. the names, employment positions, and the addresses of each person 

who received such document; 

e. the title and a brief description of the document; and 

f. the number of the request under which such document would be 

produced but for the objection. 

4. If any document responsive to a request has been destroyed, produce all documents 

describing or referencing: 

a. the contents of the lost or destroyed document; 

b. all locations in which any copy of the lost or destroyed document 

had been maintained; 

c. the date of such loss or destruction; 

d. the name of each person who ordered, authorized, and carried out 

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the destruction of any responsive document; 

e. all document retention and destruction policies in effect at the time 

any requested document was destroyed; and 

f. all efforts made to locate any responsive document alleged to have 

been lost. 

5. In producing the documents requested, indicate the specific request(s) pursuant to which 

document or group of documents is being produced. 

6. These requests should be deemed continuing, and supplemental productions should be 

provided as additional documents become available. 

7. All documents are to be produced in the following method: 

a) Single page .TIFF 

b) Color .jpg (Documents wherein reflection of importance relies on color, shall be 

produced in .jpg format) 

c) OCR at document level (All documents are to be provided with searchable text files 

with the exception of the redacted portions of redacted documents) 

d) Electronic documents and Emails are to be processed and converted from the 

electronic format to single page tiff 

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THREE REQUESTS FOR PRODUCTION 

Please refer to the Definitions and Instructions when responding to these requests. To the 

extent that any of these requests seek information considered by Defendants to be 

confidential, Plaintiff have already agreed to enter into any reasonable confidentiality 

agreement with Defendants to protect such alleged confidential information. 

1. All Documents and Communications, including but not limited to contracts or 

agreements, regarding Your “First-Of-Its-Kind” International Partnership with the FTX Entities. 

See https://www.nba.com/warriors/warriors-ftx-partnership-20211214 (accessed April 21, 

2023). 

2. 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 Gaming Squad court during NBA 2K League games; and (3) any NFTs that GSW 

offered for sale on the FTX Platform. 

3. All documents regarding any and all communications with the FTX Entities 

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

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-cv-23753-KMM 

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

 

SAM BANKMAN-FRIED, et al., 

Defendants. 

/

PLAINTIFF’S FIRST SET OF THREE REQUESTS FOR PRODUCTION TO 

DEFENDANT SHOHEI OHTANI 

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, Shohei Ohtani 

(“Ohtani”), produce the documents requested in response to these three requests. 

Dated: April 21, 2023 Respectfully submitted, 

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Florida Bar No. 984280 

adam@moskowitz-law.com 

Joseph M. Kaye 

Florida Bar No. 117520 

joseph@moskowitz-law.com 

THE MOSKOWITZ LAW FIRM, PLLC 

2 Alhambra Plaza, Suite 601 

Coral Gables, FL 33134 

Telephone: (305) 740-1423 

By: /s/ David Boies 

David Boies 

(Pro Hac Vice) 

Alex Boies 

(Pro Hac Vice) 

BOIES SCHILLER FLEXNER LLP 

333 Main Street 

Armonk, NY 10504 

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Phone: (914) 749–8200 

dboies@bsfllp.com 

By: /s/ Stephen Neal Zack 

Stephen Neal Zack 

Florida Bar No. 145215 

BOIES SCHILLER FLEXNER LLP 

100 SE 2nd St., Suite 2800 

Miami, FL 33131 

Office: 305-539-8400 

szack@bsfllp.com 

Co-Counsel for Plaintiff and the Class 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that on April 21, 2023, a true and correct copy of the foregoing was 

sent via electronic mail to counsel for Defendants. 

 By: /s/ Adam M. Moskowitz______ 

 ADAM M. MOSKOWITZ 

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DEFINITIONS AND INSTRUCTIONS 

Unless otherwise specified, the terms set forth below have the following meanings: 

1. “Ohtani,” “You,” or “Your” means Defendant Shohei Ohtani and any of his 

affiliates, representatives, or agents. 

2. “FTX Entities” means West Realm Shires Services, Inc., FTX Trading Ltd, 

Blockfolio, Inc., and any of their affiliates, subsidiaries, divisions, segments, predecessors, 

successors, officers, directors, employees, representatives, or agents. 

3. “FTX Platform” refers to the FTX Entities’ mobile application and/or web-based 

cryptocurrency investment service that places cryptocurrency trade orders on behalf of users. 

4. “YBAs” refers to the Yield-Bearing Accounts offered by the FTX Entities on the 

FTX Platform. 

5. “FTT” refers to the native cryptocurrency exchange token of the FTX Platform 

ecosystem. 

6. “FTX Platform” refers to the FTX Entities’ mobile application cryptocurrency 

investment service that places cryptocurrency trade orders on behalf of users. 

7. “Document(s)” means any written, printed, typed or other graphic matter, of any 

kind or nature, whether in hard copy or electronic format, whether the original, draft, or a copy 

and copies bearing notations or marks not found on the original, including but not limited to 

memoranda, reports, recommendations, notes, letters, envelopes, post-its, emails, telegrams, 

messages, manuscripts, studies, analyses, tests, comparisons, books, articles, pamphlets, 

magazines, newspapers, booklets, circulars, bulletins, notices, instructions, minutes, 

agreements, contracts, and all other written communications, of any type, including inter and 

intra-office communications, purchase orders, invoices, bills, receipts, questionnaires, surveys, 

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charts, graphs, videos, photographs, sketches, drawings, house sheets, tapes, voice messages or 

other recordings, print-outs or compilations from which information can be obtained or, if 

necessary, translated through detection devices into reasonably usable form, including all 

underlying or preparatory materials and drafts thereof. 

8. Unless otherwise stated in a request, the time period for which you must respond 

is beginning in January 1, 2019 and ending at the present time. 

9. “Person” or “People” means any natural person(s) or any business, legal, or 

governmental entity (or entities) or association(s). 

10. All/Each – The terms “all” and “each” shall be construed as meaning either all 

or each as necessary to bring within the scope of the discovery request all responses that might 

otherwise be construed to be outside its scope. 

11. Objections: Where an objection is made to any request, the objection shall state 

with specificity all grounds. Any ground not stated in an objection within the time provided by 

the Federal Rules of Civil Procedure, or by the Court’s order, or any extensions thereof, shall be 

waived. 

12. Whenever a reference to a business entity appears, the reference shall mean the 

business entity, its affiliated companies, partnerships, divisions, subdivisions, directors, officers, 

employees, agents, clients or other representatives of affiliated third parties. 

INSTRUCTIONS 

1. Production of documents and items requested herein shall be made at the offices of The 

Moskowitz Law Firm, P.O. Box 141609, Coral Gables, FL 33114, or for hand deliveries 

at 251 Valencia Ave #141609, Coral Gables, FL 33114, or via electronic mail to the email 

addresses provided in the signature blocks of the attorneys serving these requests. 

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2. These requests shall include all documents that are in the possession, custody or control of 

Defendant or in the possession, custody or control of the present or former agents, 

representatives, or attorneys of Defendant, or any and all persons acting on the behalf of 

Defendant, or its present or former agents, representatives, or attorneys. 

3. For any document covered by a request that is withheld from production, Defendant shall 

provide the following information in the form of a privilege log: 

a. the reasons and facts supporting any withholding; 

b. the date such document was prepared; 

c. the names, employment positions and addresses of the author or 

preparers of such document; 

d. the names, employment positions, and the addresses of each person 

who received such document; 

e. the title and a brief description of the document; and 

f. the number of the request under which such document would be 

produced but for the objection. 

4. If any document responsive to a request has been destroyed, produce all documents 

describing or referencing: 

a. the contents of the lost or destroyed document; 

b. all locations in which any copy of the lost or destroyed document 

had been maintained; 

c. the date of such loss or destruction; 

d. the name of each person who ordered, authorized, and carried out 

the destruction of any responsive document; 

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e. all document retention and destruction policies in effect at the time 

any requested document was destroyed; and 

f. all efforts made to locate any responsive document alleged to have 

been lost. 

5. In producing the documents requested, indicate the specific request(s) pursuant to which 

document or group of documents is being produced. 

6. These requests should be deemed continuing, and supplemental productions should be 

provided as additional documents become available. 

7. All documents are to be produced in the following method: 

a) Single page .TIFF 

b) Color .jpg (Documents wherein reflection of importance relies on color, shall be 

produced in .jpg format) 

c) OCR at document level (All documents are to be provided with searchable text files 

with the exception of the redacted portions of redacted documents) 

d) Electronic documents and Emails are to be processed and converted from the 

electronic format to single page tiff 

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THREE REQUESTS FOR PRODUCTION 

Please refer to the Definitions and Instructions when responding to these requests. To the 

extent that any of these requests seek information considered by Defendants to be 

confidential, Plaintiff have already agreed to enter into any reasonable confidentiality 

agreement with Defendants to protect such alleged confidential information. 

1. All Documents and Communications, including contracts or agreements, 

regarding Your Global Partnership with the FTX Entities. See 

https://www.prnewswire.com/news-releases/mlb-superstar-shohei-ohtani-joins-ftx-as-globalambassador-through-long-term-partnership-301425911.html (accessed April 21, 2023). 

2. 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 the “Shohei Does it All” advertising campaign. See 

https://www.youtube.com/watch?v=Is72XSKuUqA (accessed April 21, 2023). 

3. All documents regarding any and all communications with the FTX Entities 

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

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-cv-23753-KMM 

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

 

SAM BANKMAN-FRIED, et al., 

Defendants. 

/

PLAINTIFF’S FIRST SET OF THREE REQUESTS FOR PRODUCTION TO 

DEFENDANT NAOMI OSAKA 

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, Naomi Osaka 

(“Osaka”), produce the documents requested in response to these three requests. 

Dated: April 21, 2023 Respectfully submitted, 

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Florida Bar No. 984280 

adam@moskowitz-law.com 

Joseph M. Kaye 

Florida Bar No. 117520 

joseph@moskowitz-law.com 

THE MOSKOWITZ LAW FIRM, PLLC 

2 Alhambra Plaza, Suite 601 

Coral Gables, FL 33134 

Telephone: (305) 740-1423 

By: /s/ David Boies 

David Boies 

(Pro Hac Vice) 

Alex Boies 

(Pro Hac Vice) 

BOIES SCHILLER FLEXNER LLP 

333 Main Street 

Armonk, NY 10504 

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Phone: (914) 749–8200 

dboies@bsfllp.com 

By: /s/ Stephen Neal Zack 

Stephen Neal Zack 

Florida Bar No. 145215 

BOIES SCHILLER FLEXNER LLP 

100 SE 2nd St., Suite 2800 

Miami, FL 33131 

Office: 305-539-8400 

szack@bsfllp.com 

Co-Counsel for Plaintiff and the Class 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that on April 21, 2023, a true and correct copy of the foregoing was 

sent via electronic mail to counsel for Defendants. 

 By: /s/ Adam M. Moskowitz______ 

 ADAM M. MOSKOWITZ 

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DEFINITIONS AND INSTRUCTIONS 

Unless otherwise specified, the terms set forth below have the following meanings: 

1. “Osaka,” “You,” or “Your” means Defendant Naomi Osaka and any of her 

affiliates, representatives, or agents. 

2. “FTX Entities” means West Realm Shires Services, Inc., FTX Trading Ltd, 

Blockfolio, Inc., and any of their affiliates, subsidiaries, divisions, segments, predecessors, 

successors, officers, directors, employees, representatives, or agents. 

3. “FTX Platform” refers to the FTX Entities’ mobile application and/or web-based 

cryptocurrency investment service that places cryptocurrency trade orders on behalf of users. 

4. “YBAs” refers to the Yield-Bearing Accounts offered by the FTX Entities on the 

FTX Platform. 

5. “FTT” refers to the native cryptocurrency exchange token of the FTX Platform 

ecosystem. 

6. “FTX Platform” refers to the FTX Entities’ mobile application cryptocurrency 

investment service that places cryptocurrency trade orders on behalf of users. 

7. “Document(s)” means any written, printed, typed or other graphic matter, of any 

kind or nature, whether in hard copy or electronic format, whether the original, draft, or a copy 

and copies bearing notations or marks not found on the original, including but not limited to 

memoranda, reports, recommendations, notes, letters, envelopes, post-its, emails, telegrams, 

messages, manuscripts, studies, analyses, tests, comparisons, books, articles, pamphlets, 

magazines, newspapers, booklets, circulars, bulletins, notices, instructions, minutes, 

agreements, contracts, and all other written communications, of any type, including inter and 

intra-office communications, purchase orders, invoices, bills, receipts, questionnaires, surveys, 

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charts, graphs, videos, photographs, sketches, drawings, house sheets, tapes, voice messages or 

other recordings, print-outs or compilations from which information can be obtained or, if 

necessary, translated through detection devices into reasonably usable form, including all 

underlying or preparatory materials and drafts thereof. 

8. Unless otherwise stated in a request, the time period for which you must respond 

is beginning in January 1, 2019 and ending at the present time. 

9. “Person” or “People” means any natural person(s) or any business, legal, or 

governmental entity (or entities) or association(s). 

10. All/Each – The terms “all” and “each” shall be construed as meaning either all 

or each as necessary to bring within the scope of the discovery request all responses that might 

otherwise be construed to be outside its scope. 

11. Objections: Where an objection is made to any request, the objection shall state 

with specificity all grounds. Any ground not stated in an objection within the time provided by 

the Federal Rules of Civil Procedure, or by the Court’s order, or any extensions thereof, shall be 

waived. 

12. Whenever a reference to a business entity appears, the reference shall mean the 

business entity, its affiliated companies, partnerships, divisions, subdivisions, directors, officers, 

employees, agents, clients or other representatives of affiliated third parties. 

INSTRUCTIONS 

1. Production of documents and items requested herein shall be made at the offices of The 

Moskowitz Law Firm, P.O. Box 141609, Coral Gables, FL 33114, or for hand deliveries 

at 251 Valencia Ave #141609, Coral Gables, FL 33114, or via electronic mail to the email 

addresses provided in the signature blocks of the attorneys serving these requests. 

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2. These requests shall include all documents that are in the possession, custody or control of 

Defendant or in the possession, custody or control of the present or former agents, 

representatives, or attorneys of Defendant, or any and all persons acting on the behalf of 

Defendant, or its present or former agents, representatives, or attorneys. 

3. For any document covered by a request that is withheld from production, Defendant shall 

provide the following information in the form of a privilege log: 

a. the reasons and facts supporting any withholding; 

b. the date such document was prepared; 

c. the names, employment positions and addresses of the author or 

preparers of such document; 

d. the names, employment positions, and the addresses of each person 

who received such document; 

e. the title and a brief description of the document; and 

f. the number of the request under which such document would be 

produced but for the objection. 

4. If any document responsive to a request has been destroyed, produce all documents 

describing or referencing: 

a. the contents of the lost or destroyed document; 

b. all locations in which any copy of the lost or destroyed document 

had been maintained; 

c. the date of such loss or destruction; 

d. the name of each person who ordered, authorized, and carried out 

the destruction of any responsive document; 

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e. all document retention and destruction policies in effect at the time 

any requested document was destroyed; and 

f. all efforts made to locate any responsive document alleged to have 

been lost. 

5. In producing the documents requested, indicate the specific request(s) pursuant to which 

document or group of documents is being produced. 

6. These requests should be deemed continuing, and supplemental productions should be 

provided as additional documents become available. 

7. All documents are to be produced in the following method: 

a) Single page .TIFF 

b) Color .jpg (Documents wherein reflection of importance relies on color, shall be 

produced in .jpg format) 

c) OCR at document level (All documents are to be provided with searchable text files 

with the exception of the redacted portions of redacted documents) 

d) Electronic documents and Emails are to be processed and converted from the 

electronic format to single page tiff 

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THREE REQUESTS FOR PRODUCTION 

Please refer to the Definitions and Instructions when responding to these requests. To the 

extent that any of these requests seek information considered by Defendants to be 

confidential, Plaintiff have already agreed to enter into any reasonable confidentiality 

agreement with Defendants to protect such alleged confidential information. 

1. All Documents and Communications, including contracts or agreements, 

regarding Your Global Partnership with the FTX Entities. See 

https://www.prnewswire.com/news-releases/naomi-osaka-world-renowned-tennis-player-andactivist-becomes-global-ambassador-and-shareholder-of-ftx-with-long-term-partnership-toincrease-access-and-opportunity-for-women-in-crypto-301506633.html (accessed April 21, 

2023). 

2. 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) through wearing the FTX logo on the kit Defendant wore at tournaments, 

including the 2022 Miami Open, and (2) through any and all content you directed, created, 

produced, or participated in in association with the FTX Entities designed to promote the FTX 

Platform, FTT, and/or YBAs, such as the advertisement viewable here: 

https://youtu.be/pkuf8avR50k (accessed April 21, 2023). 

3. All documents regarding any and all communications with the FTX Entities 

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

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-cv-23753-KMM 

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

 

SAM BANKMAN-FRIED, et al., 

Defendants. 

/

NOTICE OF TAKING THE VIDEOTAPED DEPOSITION OF DEFENDANT 

GOLDEN STATE WARRIORS LLC’S RULE 30(b)(6) REPRESENTATIVE(S) 

 Pursuant to Federal Rule of Civil Procedure 30(b)(6), Plaintiff’s counsel will take the 

deposition of the below-named person/entity on the date, time, and at the location indicated. 

DEPONENT: Defendant Golden State Warriors LLC, (the “GSW”), by and 

through GSW’ corporate representative(s) with knowledge 

of the four topics listed in Exhibit A, pursuant to Federal 

Rule of Civil Procedure 30(b)(6). 

DATE: May 8, 2023 

TIME: 10:00 AM (PDT) // 1:00 PM (EDT) 

LOCATION: Boies, Schiller Flexner, LLP 

725 S Figueroa Street, 31st Floor 

Los Angeles, CA 90017 

Phone (213) 629–9040 

The aforesaid deposition will be before a court reporter, an officer authorized by law to 

administer oaths and take depositions in the State of California. The deposition is being taken for 

the purpose of discovery, for use at trial, or both, or for such other purposes as are permitted under 

the Federal and Local Rules of Civil Procedure. 

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Pursuant to Federal Rule of Civil Procedure 30(b)(6), Defendant Golden State Warriors 

LLC (the “GSW”) shall both designate one or more officers, directors, managing agents, or other 

persons to testify on its behalf on each topic listed on Exhibit A attached hereto. 

Dated: April 21, 2023 Respectfully submitted, 

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Florida Bar No. 984280 

adam@moskowitz-law.com 

Joseph M. Kaye 

Florida Bar No. 117520 

joseph@moskowitz-law.com 

THE MOSKOWITZ LAW FIRM, PLLC 

2 Alhambra Plaza, Suite 601 

Coral Gables, FL 33134 

Telephone: (305) 740-1423 

By: /s/ David Boies 

David Boies 

(Pro Hac Vice) 

Alex Boies 

(Pro Hac Vice) 

BOIES SCHILLER FLEXNER LLP 

333 Main Street 

Armonk, NY 10504 

Phone: (914) 749–8200 

dboies@bsfllp.com 

By: /s/ Stephen Neal Zack 

Stephen Neal Zack 

Florida Bar No. 145215 

BOIES SCHILLER FLEXNER LLP 

100 SE 2nd St., Suite 2800 

Miami, FL 33131 

Office: 305-539-8400 

szack@bsfllp.com 

Co-Counsel for Plaintiff and the Class 

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CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a true and correct copy of the forgoing was filed on April 21, 

2023, via the Court’s CM/ECF system, which will send notification of such filing to all attorneys 

of record. 

 By: /s/ Adam M. Moskowitz______ 

 ADAM M. MOSKOWITZ 

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EXHIBIT A 

I. DEFINITIONS AND INSTRUCTIONS 

Unless otherwise specified, the terms set forth below have the following meanings: 

1. “GSW,” “You,” or “Your” means Defendant, Golden State Warriors LLC, any 

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

employees, representatives, or agents. 

2. “FTX Entities” means West Realm Shires Services, Inc., FTX Trading Ltd, 

Blockfolio, Inc., and any of their affiliates, subsidiaries, divisions, segments, predecessors, 

successors, officers, directors, employees, representatives, or agents. 

3. “FTX Platform” refers to the FTX Entities’ mobile application and/or web-based 

cryptocurrency investment service that places cryptocurrency trade orders on behalf of users. 

4. “YBAs” refers to the Yield-Bearing Accounts offered by the FTX Entities on the 

FTX Platform. 

5. “FTT” refers to the native cryptocurrency exchange token of the FTX Platform 

ecosystem. 

6. “FTX Platform” refers to the FTX Entities’ mobile application cryptocurrency 

investment service that places cryptocurrency trade orders on behalf of users. 

7. “Document(s)” means any written, printed, typed or other graphic matter, of any 

kind or nature, whether in hard copy or electronic format, whether the original, draft, or a copy 

and copies bearing notations or marks not found on the original, including but not limited to 

memoranda, reports, recommendations, notes, letters, envelopes, post-its, emails, telegrams, 

messages, manuscripts, studies, analyses, tests, comparisons, books, articles, pamphlets, 

magazines, newspapers, booklets, circulars, bulletins, notices, instructions, minutes, 

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agreements, contracts, and all other written communications, of any type, including inter and 

intra-office communications, purchase orders, invoices, bills, receipts, questionnaires, surveys, 

charts, graphs, videos, photographs, sketches, drawings, house sheets, tapes, voice messages or 

other recordings, print-outs or compilations from which information can be obtained or, if 

necessary, translated through detection devices into reasonably usable form, including all 

underlying or preparatory materials and drafts thereof. 

8. “Person” or “People” means any natural person(s) or any business, legal, or 

governmental entity (or entities) or association(s). 

9. All/Each – The terms “all” and “each” shall be construed as meaning either all 

or each as necessary to bring within the scope of the discovery request all responses that might 

otherwise be construed to be outside its scope. 

10. Objections: Where an objection is made to any request, the objection shall state 

with specificity all grounds. Any ground not stated in an objection within the time provided by 

the Federal Rules of Civil Procedure, or by the Court’s order, or any extensions thereof, shall 

be waived. 

11. Whenever a reference to a business entity appears, the reference shall mean the 

business entity, its affiliated companies, partnerships, divisions, subdivisions, directors, officers, 

employees, agents, clients or other representatives of affiliated third parties. 

12. Unless otherwise stated in a request, the time period for which you must respond 

is beginning in January 1, 2019 and ending at the present time. 

 

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II. FOUR DEPOSITION SUBJECTS 

Pursuant to Rule 30(b)(6), the GSW shall designate and produce for deposition one or more 

of its officers, directors, managing agents, or other persons who are knowledgeable about and 

consent to testify on its behalf concerning the following subject matters: 

1. All Documents and responses provided in response to Plaintiffs’ request for 

production, each dated and served on April 21, 2023. 

2. All contracts or agreements and circumstances regarding Your “First-Of-ItsKind” International Partnership with the FTX Entities. See 

https://www.nba.com/warriors/warriors-ftx-partnership-20211214 (accessed April 21, 2023). 

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 Gaming Squad court during NBA 2K League games; and (3) any NFTs that GSW 

offered for sale on the FTX Platform. 

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. 

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-cv-23753-KMM 

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

 

SAM BANKMAN-FRIED, et al., 

Defendants. 

/

NOTICE OF TAKING THE VIDEOTAPED DEPOSITION OF 

DEFENDANT STEPHEN CURRY 

 Pursuant to Federal Rule of Civil Procedure 30, Plaintiff’s counsel will take the deposition 

of the below-named person/entity on the date, time, and at the location indicated. 

DEPONENT: Defendant Stephen Curry 

DATE: May 9, 2023 

TIME: 10:00 AM (PDT) // 1:00 PM (EDT) 

LOCATION: Boies, Schiller Flexner, LLP 

725 S Figueroa Street, 31st Floor 

Los Angeles, CA 90017 

Phone (213) 629–9040 

The aforesaid deposition will be before a court reporter, an officer authorized by law to 

administer oaths and take depositions in the State of California. The deposition is being taken for 

the purpose of discovery, for use at trial, or both, or for such other purposes as are permitted under 

the Federal and Local Rules of Civil Procedure. 

 

Case 1:22-cv-23753-KMM Document 162-1 Entered on FLSD Docket 04/26/2023 Page 43 of

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Edwin Garrison, et al. v. Samuel Bankman-Fried, et al. 

Case No. 1:22-cv-23753-KMM 

2 

Dated: April 21, 2023 Respectfully submitted, 

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Florida Bar No. 984280 

adam@moskowitz-law.com 

Joseph M. Kaye 

Florida Bar No. 117520 

joseph@moskowitz-law.com 

THE MOSKOWITZ LAW FIRM, PLLC 

2 Alhambra Plaza, Suite 601 

Coral Gables, FL 33134 

Telephone: (305) 740-1423 

By: /s/ David Boies 

David Boies 

(Pro Hac Vice) 

Alex Boies 

(Pro Hac Vice) 

BOIES SCHILLER FLEXNER LLP 

333 Main Street 

Armonk, NY 10504 

Phone: (914) 749–8200 

dboies@bsfllp.com 

By: /s/ Stephen Neal Zack 

Stephen Neal Zack 

Florida Bar No. 145215 

BOIES SCHILLER FLEXNER LLP 

100 SE 2nd St., Suite 2800 

Miami, FL 33131 

Office: 305-539-8400 

szack@bsfllp.com 

Co-Counsel for Plaintiff and the Class 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a true and correct copy of the forgoing was filed on April 21, 

2023, via Court’s CM/ECF system, which will send notification to all attorneys of record. 

 By: /s/ Adam M. Moskowitz______ 

 ADAM M. MOSKOWITZ 

Case 1:22-cv-23753-KMM Document 162-1 Entered on FLSD Docket 04/26/2023 Page 44 of

50
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-cv-23753-KMM 

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

 

SAM BANKMAN-FRIED, et al., 

Defendants. 

/

NOTICE OF TAKING THE VIDEOTAPED DEPOSITION OF 

DEFENDANT LAWRENCE GENE DAVID 

 Pursuant to Federal Rule of Civil Procedure 30, Plaintiff’s counsel will take the deposition 

of the below-named person/entity on the date, time, and at the location indicated. 

DEPONENT: Defendant Lawrence Gene David 

DATE: May 11, 2023 

TIME: 10:00 AM (PDT) // 1:00 PM (EDT) 

LOCATION: Boies, Schiller Flexner, LLP 

725 S Figueroa Street, 31st Floor 

Los Angeles, CA 90017 

Phone (213) 629–9040 

The aforesaid deposition will be before a court reporter, an officer authorized by law to 

administer oaths and take depositions in the State of California. The deposition is being taken for 

the purpose of discovery, for use at trial, or both, or for such other purposes as are permitted under 

the Federal and Local Rules of Civil Procedure. 

Dated: April 21, 2023 Respectfully submitted, 

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Case 1:22-cv-23753-KMM Document 162-1 Entered on FLSD Docket 04/26/2023 Page 45 of

50
Edwin Garrison, et al. v. Samuel Bankman-Fried, et al. 

Case No. 1:22-cv-23753-KMM 

2 

Florida Bar No. 984280 

adam@moskowitz-law.com 

Joseph M. Kaye 

Florida Bar No. 117520 

joseph@moskowitz-law.com 

THE MOSKOWITZ LAW FIRM, PLLC 

2 Alhambra Plaza, Suite 601 

Coral Gables, FL 33134 

Telephone: (305) 740-1423 

By: /s/ David Boies 

David Boies 

(Pro Hac Vice) 

Alex Boies 

(Pro Hac Vice) 

BOIES SCHILLER FLEXNER LLP 

333 Main Street 

Armonk, NY 10504 

Phone: (914) 749–8200 

dboies@bsfllp.com 

By: /s/ Stephen Neal Zack 

Stephen Neal Zack 

Florida Bar No. 145215 

BOIES SCHILLER FLEXNER LLP 

100 SE 2nd St., Suite 2800 

Miami, FL 33131 

Office: 305-539-8400 

szack@bsfllp.com 

Co-Counsel for Plaintiff and the Class 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a true and correct copy of the forgoing was filed on April 21, 

2023, via the Court’s CM/ECF system, which will send notification of such filing to all attorneys 

of record. 

 By: /s/ Adam M. Moskowitz______ 

 ADAM M. MOSKOWITZ 

Case 1:22-cv-23753-KMM Document 162-1 Entered on FLSD Docket 04/26/2023 Page 46 of

50
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-cv-23753-KMM 

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

 

SAM BANKMAN-FRIED, et al., 

Defendants. 

/

NOTICE OF TAKING THE VIDEOTAPED DEPOSITION OF 

DEFENDANT SHOHEI OHTANI 

 Pursuant to Federal Rule of Civil Procedure 30, Plaintiff’s counsel will take the deposition 

of the below-named person/entity on the date, time, and at the location indicated. 

DEPONENT: Defendant Shohei Ohtani 

DATE: May 12, 2023 

TIME: 10:00 AM (PDT) // 1:00 PM (EDT) 

LOCATION: Boies, Schiller Flexner, LLP 

725 S Figueroa Street, 31st Floor 

Los Angeles, CA 90017 

Phone (213) 629–9040 

The aforesaid deposition will be before a court reporter, an officer authorized by law to 

administer oaths and take depositions in the State of California. The deposition is being taken for 

the purpose of discovery, for use at trial, or both, or for such other purposes as are permitted under 

the Federal and Local Rules of Civil Procedure. 

Dated: April 21, 2023 Respectfully submitted, 

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Case 1:22-cv-23753-KMM Document 162-1 Entered on FLSD Docket 04/26/2023 Page 47 of

50
Edwin Garrison, et al. v. Samuel Bankman-Fried, et al. 

Case No. 1:22-cv-23753-KMM 

2 

Florida Bar No. 984280 

adam@moskowitz-law.com 

Joseph M. Kaye 

Florida Bar No. 117520 

joseph@moskowitz-law.com 

THE MOSKOWITZ LAW FIRM, PLLC 

2 Alhambra Plaza, Suite 601 

Coral Gables, FL 33134 

Telephone: (305) 740-1423 

By: /s/ David Boies 

David Boies 

(Pro Hac Vice) 

Alex Boies 

(Pro Hac Vice) 

BOIES SCHILLER FLEXNER LLP 

333 Main Street 

Armonk, NY 10504 

Phone: (914) 749–8200 

dboies@bsfllp.com 

By: /s/ Stephen Neal Zack 

Stephen Neal Zack 

Florida Bar No. 145215 

BOIES SCHILLER FLEXNER LLP 

100 SE 2nd St., Suite 2800 

Miami, FL 33131 

Office: 305-539-8400 

szack@bsfllp.com 

Co-Counsel for Plaintiff and the Class 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a true and correct copy of the forgoing was filed on April 21, 

2023, via the Court’s CM/ECF system, which will send notification of such filing to all attorneys 

of record. 

 By: /s/ Adam M. Moskowitz______ 

 ADAM M. MOSKOWITZ 

Case 1:22-cv-23753-KMM Document 162-1 Entered on FLSD Docket 04/26/2023 Page 48 of

50
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-cv-23753-KMM 

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

 

SAM BANKMAN-FRIED, et al., 

Defendants. 

/

NOTICE OF TAKING THE VIDEOTAPED DEPOSITION OF 

DEFENDANT NAOMI OSAKA 

 Pursuant to Federal Rule of Civil Procedure 30, Plaintiff’s counsel will take the deposition 

of the below-named person/entity on the date, time, and at the location indicated. 

DEPONENT: Defendant Naomi Osaka 

DATE: May 10, 2023 

TIME: 10:00 AM (PDT) // 1:00 PM (EDT) 

LOCATION: Boies, Schiller Flexner, LLP 

725 S Figueroa Street, 31st Floor 

Los Angeles, CA 90017 

Phone (213) 629–9040 

The aforesaid deposition will be before a court reporter, an officer authorized by law to 

administer oaths and take depositions in the State of California. The deposition is being taken for 

the purpose of discovery, for use at trial, or both, or for such other purposes as are permitted under 

the Federal and Local Rules of Civil Procedure. 

Dated: April 21, 2023 Respectfully submitted, 

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Case 1:22-cv-23753-KMM Document 162-1 Entered on FLSD Docket 04/26/2023 Page 49 of

50
Edwin Garrison, et al. v. Samuel Bankman-Fried, et al. 

Case No. 1:22-cv-23753-KMM 

2 

Florida Bar No. 984280 

adam@moskowitz-law.com 

Joseph M. Kaye 

Florida Bar No. 117520 

joseph@moskowitz-law.com 

THE MOSKOWITZ LAW FIRM, PLLC 

2 Alhambra Plaza, Suite 601 

Coral Gables, FL 33134 

Telephone: (305) 740-1423 

By: /s/ David Boies 

David Boies 

(Pro Hac Vice) 

Alex Boies 

(Pro Hac Vice) 

BOIES SCHILLER FLEXNER LLP 

333 Main Street 

Armonk, NY 10504 

Phone: (914) 749–8200 

dboies@bsfllp.com 

By: /s/ Stephen Neal Zack 

Stephen Neal Zack 

Florida Bar No. 145215 

BOIES SCHILLER FLEXNER LLP 

100 SE 2nd St., Suite 2800 

Miami, FL 33131 

Office: 305-539-8400 

szack@bsfllp.com 

Co-Counsel for Plaintiff and the Class 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a true and correct copy of the forgoing was filed on April 21, 

2023, via the Court’s CM/ECF system, which will send notification of such filing to all attorneys 

of record. 

 By: /s/ Adam M. Moskowitz______ 

 ADAM M. MOSKOWITZ 

Case 1:22-cv-23753-KMM Document 162-1 Entered on FLSD Docket 04/26/2023 Page 50 of

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