Composite Exhibit B

Case 1:22-cv-23753-KMM Document 213-2 Entered on FLSD Docket 05/30/2023 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 TOM BRADY

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, Tom Brady

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

Dated: May 26, 2023 Respectfully submitted,

By: /s/ Adam Moskowitz

Adam M. Moskowitz

Florida Bar No. 984280

Joseph M. Kaye

Florida Bar No. 117520

THE MOSKOWITZ LAW FIRM, PLLC

3250 Mary Street, Suite 202

Miami, FL 33133

Mailing Address:

P.O. Box 653409

Miami, FL 33175

Telephone: (305) 740-1423

adam@moskowitz-law.com 

joseph@moskowitz-law.com

By: /s/ David Boies

David Boies

(Pro Hac Vice)

Alex Boies

(Pro Hac Vice)

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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

By: /s/Jose M. Ferrer

Jose Ferrer

Florida Bar No. 173746

Michelle Genet Bernstein

Florida Bar No. 1030736

MARK MIGDAL HAYDEN LLP

80 SW 8th Street, Suite 1999

Miami, FL 33130

Office: 305-374-0440

jose@markmigdal.com

michelle@markmigdal.com

Co-Counsel for Plaintiff and the Class

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 26, 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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3

DEFINITIONS AND INSTRUCTIONS

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

1. “Brady,” “You,” or “Your” means Defendant Tom Brady 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.

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

5

INSTRUCTIONS

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

Moskowitz Law Firm, P.O. Box 653409, Miami, FL 33133, or via electronic mail to the 

email 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 

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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;

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.wsj.com/articles/tom-brady-and-gisele-bundchen-to-star-in-20-million-campaignfor-crypto-exchange-11631116800?mod=article_inline (accessed May 26, 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 “You In?,” “Trade Everything,” and “Invest Better” advertising campaigns. 

See https://www.youtube.com/watch?v=_aCGMyrFn-8 (accessed May 26, 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 213-2 Entered on FLSD Docket 05/30/2023 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 GISELE BÜNDCHEN

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, Gisele Bündchen 

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

Dated: May 26, 2023 Respectfully submitted,

By: /s/ Adam Moskowitz 

Adam M. Moskowitz 

Florida Bar No. 984280 

Joseph M. Kaye 

Florida Bar No. 117520 

THE MOSKOWITZ LAW FIRM, PLLC

3250 Mary Street, Suite 202 

Miami, FL 33133 

Mailing Address:

P.O. Box 653409 

Miami, FL 33175 

Telephone: (305) 740-1423 

adam@moskowitz-law.com 

joseph@moskowitz-law.com 

By: /s/ David Boies

David Boies 

(Pro Hac Vice) 

Alex Boies

(Pro Hac Vice) 

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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

By: /s/Jose M. Ferrer

Jose Ferrer

Florida Bar No. 173746 

Michelle Genet Bernstein

Florida Bar No. 1030736 

MARK MIGDAL HAYDEN LLP

80 SW 8th Street, Suite 1999 

Miami, FL 33130 

Office: 305-374-0440 

jose@markmigdal.com

michelle@markmigdal.com

Co-Counsel for Plaintiff and the Class

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 26, 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. “Bündchen,” “You,” or “Your” means Defendant Gisele Bündchen 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.

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INSTRUCTIONS

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

Moskowitz Law Firm, P.O. Box 653409, Miami, FL 33133 or via electronic mail to the 

email 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 

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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;

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.wsj.com/articles/tom-brady-and-gisele-bundchen-to-star-in-20-millioncampaignfor-crypto-exchange-11631116800?mod=article_inline (accessed May 26, 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 “You In?,” “Trade Everything,” and “Invest Better” advertising campaigns. 

See https://www.youtube.com/watch?v=_aCGMyrFn-8 (accessed May 26, 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 213-2 Entered on FLSD Docket 05/30/2023 Page 15 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 UDONIS HASLEM

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, Udonis Haslem

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

Dated: May 26, 2023 Respectfully submitted,

By: /s/ Adam Moskowitz

Adam M. Moskowitz

Florida Bar No. 984280

Joseph M. Kaye

Florida Bar No. 117520

THE MOSKOWITZ LAW FIRM, PLLC

3250 Mary Street, Suite 202

Miami, FL 33133

Mailing Address:

P.O. Box 653409

Miami, FL 33175

Telephone: (305) 740-1423

adam@moskowitz-law.com 

joseph@moskowitz-law.com

By: /s/ David Boies

David Boies

(Pro Hac Vice)

Alex Boies

(Pro Hac Vice)

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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

By: /s/Jose M. Ferrer

Jose Ferrer

Florida Bar No. 173746

Michelle Genet Bernstein

Florida Bar No. 1030736

MARK MIGDAL HAYDEN LLP

80 SW 8th Street, Suite 1999

Miami, FL 33130

Office: 305-374-0440

jose@markmigdal.com

michelle@markmigdal.com

Co-Counsel for Plaintiff and the Class

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 26, 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. “Haslem,” “You,” or “Your” means Defendant Udonis Haslem 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.

Case 1:22-cv-23753-KMM Document 213-2 Entered on FLSD Docket 05/30/2023 Page 19 of

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INSTRUCTIONS

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

Moskowitz Law Firm, P.O. Box 653409, Miami, FL 33133 or via electronic mail to the 

email 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 

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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;

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 Partnership with the FTX Entities. See https://heatnation.com/media/udonishaslem-reveals-ftx-gypped-him-out-of-15m/ (accessed May 26, 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 FTX Charity Hackathon and “You In?” advertising campaign. See

https://www.youtube.com/watch?v=4sD8uLYzzwM (accessed May 26, 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 213-2 Entered on FLSD Docket 05/30/2023 Page 22 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 TREVOR LAWRENCE

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

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

Dated: May 26, 2023 Respectfully submitted,

By: /s/ Adam Moskowitz

Adam M. Moskowitz

Florida Bar No. 984280

Joseph M. Kaye

Florida Bar No. 117520

THE MOSKOWITZ LAW FIRM, PLLC

3250 Mary Street, Suite 202

Miami, FL 33133

Mailing Address:

P.O. Box 653409

Miami, FL 33175

Telephone: (305) 740-1423

adam@moskowitz-law.com 

joseph@moskowitz-law.com

By: /s/ David Boies

David Boies

(Pro Hac Vice)

Alex Boies

(Pro Hac Vice)

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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

By: /s/Jose M. Ferrer

Jose Ferrer

Florida Bar No. 173746

Michelle Genet Bernstein

Florida Bar No. 1030736

MARK MIGDAL HAYDEN LLP

80 SW 8th Street, Suite 1999

Miami, FL 33130

Office: 305-374-0440

jose@markmigdal.com

michelle@markmigdal.com

Co-Counsel for Plaintiff and the Class

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 26, 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

Case 1:22-cv-23753-KMM Document 213-2 Entered on FLSD Docket 05/30/2023 Page 24 of

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DEFINITIONS AND INSTRUCTIONS

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

1. “Lawrence,” “You,” or “Your” means Defendant Trevor Lawrence 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.

Case 1:22-cv-23753-KMM Document 213-2 Entered on FLSD Docket 05/30/2023 Page 26 of

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

5

INSTRUCTIONS

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

Moskowitz Law Firm, P.O. Box 653409, Miami, FL 33133 or via electronic mail to the 

email 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 

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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;

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 Partnership with the FTX Entities. See https://decrypt.co/69064/nfl-trevorlawrence-signs-endorsement-deal-with-blockfolio-ftx (accessed May 26, 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 FTX Blockfolio, “The FTX Podcast,” and “You In?” advertising campaign. See

https://blockpaths.com/the-ftx-podcast-67-trevor-lawrence-the-jacksonvillejaguarsquarterback/ (accessed May 26, 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 213-2 Entered on FLSD Docket 05/30/2023 Page 29 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 KEVIN O’LEARY

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, Kevin O’Leary

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

Dated: May 26, 2023 Respectfully submitted,

By: /s/ Adam Moskowitz

Adam M. Moskowitz

Florida Bar No. 984280

Joseph M. Kaye

Florida Bar No. 117520

THE MOSKOWITZ LAW FIRM, PLLC

3250 Mary Street, Suite 202

Miami, FL 33133

Mailing Address:

P.O. Box 653409

Miami, FL 33175

Telephone: (305) 740-1423

adam@moskowitz-law.com 

joseph@moskowitz-law.com

By: /s/ David Boies

David Boies

(Pro Hac Vice)

Alex Boies

(Pro Hac Vice)

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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

By: /s/Jose M. Ferrer

Jose Ferrer

Florida Bar No. 173746

Michelle Genet Bernstein

Florida Bar No. 1030736

MARK MIGDAL HAYDEN LLP

80 SW 8th Street, Suite 1999

Miami, FL 33130

Office: 305-374-0440

jose@markmigdal.com

michelle@markmigdal.com

Co-Counsel for Plaintiff and the Class

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 26, 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

Case 1:22-cv-23753-KMM Document 213-2 Entered on FLSD Docket 05/30/2023 Page 31 of

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DEFINITIONS AND INSTRUCTIONS

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

1. “Bündchen,” “You,” or “Your” means Defendant Kevin O’Leary 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,

Case 1:22-cv-23753-KMM Document 213-2 Entered on FLSD Docket 05/30/2023 Page 32 of

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

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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.

Case 1:22-cv-23753-KMM Document 213-2 Entered on FLSD Docket 05/30/2023 Page 33 of

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

5

INSTRUCTIONS

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

Moskowitz Law Firm, P.O. Box 653409, Miami, FL 33133 or via electronic mail to the 

email 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 

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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;

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

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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 Partnership with the FTX Entities. See https://www.prnewswire.com/news-releases/ftx-andkevin-oleary-announce-long-term-investment-and-spokesperson-relationship-301352189.html 

(accessed May 26, 2023).

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

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

FTX Charity Hackathon and “Rigorous Standards” advertising campaigns. See

https://www.nbcmiami.com/entertainment/6-in-the-mix/shark-tank-star-kevin-oleary-taking-partin-charity-hackathon/2711510/ (accessed May 26, 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 213-2 Entered on FLSD Docket 05/30/2023 Page 36 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 SHAQUILLE O’NEAL

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, Shaquille O’Neal

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

Dated: May 26, 2023 Respectfully submitted,

By: /s/ Adam Moskowitz

Adam M. Moskowitz

Florida Bar No. 984280

Joseph M. Kaye

Florida Bar No. 117520

THE MOSKOWITZ LAW FIRM, PLLC

3250 Mary Street, Suite 202

Miami, FL 33133

Mailing Address:

P.O. Box 653409

Miami, FL 33175

Telephone: (305) 740-1423

adam@moskowitz-law.com 

joseph@moskowitz-law.com

By: /s/ David Boies

David Boies

(Pro Hac Vice)

Alex Boies

(Pro Hac Vice)

Case 1:22-cv-23753-KMM Document 213-2 Entered on FLSD Docket 05/30/2023 Page 37 of

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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

By: /s/Jose M. Ferrer

Jose Ferrer

Florida Bar No. 173746

Michelle Genet Bernstein

Florida Bar No. 1030736

MARK MIGDAL HAYDEN LLP

80 SW 8th Street, Suite 1999

Miami, FL 33130

Office: 305-374-0440

jose@markmigdal.com

michelle@markmigdal.com

Co-Counsel for Plaintiff and the Class

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 26, 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. “O’Neal,” “You,” or “Your” means Defendant Shaquille O’Neal 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,

Case 1:22-cv-23753-KMM Document 213-2 Entered on FLSD Docket 05/30/2023 Page 39 of

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

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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.

Case 1:22-cv-23753-KMM Document 213-2 Entered on FLSD Docket 05/30/2023 Page 40 of

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

5

INSTRUCTIONS

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

Moskowitz Law Firm, P.O. Box 653409, Miami, FL 33133 or via electronic mail to the 

email 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 

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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;

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 Partnership with the FTX Entities. See

https://twitter.com/FTX_Official/status/1532119977381208066?s=20&t=5wTm55FDE6c0cC

D9vCndYg (accessed May 26, 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 Shaq’s Fun House, “the FTX Podcast,” FTX Off the Grid, and “You In?” advertising 

campaign. See https://twitter.com/SHAQ/status/1521960873639784449 (accessed May 26, 

2023); https://open.spotify.com/episode/2lq0BHiZb88xNRdZ9wUes4 (accessed May 26, 

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 DAVID ORTIZ

Plaintiff, pursuant to Fed. R. Civ. P. 26 and 34, requests that Defendant, David Ortiz

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

Dated: May 26, 2023 Respectfully submitted,

By: /s/ Adam Moskowitz

Adam M. Moskowitz

Florida Bar No. 984280

Joseph M. Kaye

Florida Bar No. 117520

THE MOSKOWITZ LAW FIRM, PLLC

3250 Mary Street, Suite 202

Miami, FL 33133

Mailing Address:

P.O. Box 653409

Miami, FL 33175

Telephone: (305) 740-1423

adam@moskowitz-law.com 

joseph@moskowitz-law.com

By: /s/ David Boies

David Boies

(Pro Hac Vice)

Alex Boies

(Pro Hac Vice)

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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

By: /s/Jose M. Ferrer

Jose Ferrer

Florida Bar No. 173746

Michelle Genet Bernstein

Florida Bar No. 1030736

MARK MIGDAL HAYDEN LLP

80 SW 8th Street, Suite 1999

Miami, FL 33130

Office: 305-374-0440

jose@markmigdal.com

michelle@markmigdal.com

Co-Counsel for Plaintiff and the Class

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 26, 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. “Ortiz,” “You,” or “Your” means Defendant David Ortiz 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.

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INSTRUCTIONS

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

Moskowitz Law Firm, P.O. Box 653409, Miami, FL 33133 or via electronic mail to the 

email 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 

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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;

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 Partnership with the FTX Entities. See https://davidortiz.com/red-sox-legenddavid-ortiz-signs-multiyear-ftx-deal/ (accessed May 26, 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 FTX Charity Hackathon and “You In?” advertising campaign. See

https://www.ispot.tv/ad/qSlm/ftx-big-papi-is-in (accessed May 26, 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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