Page 1 of 4

Diby Ako v. Arriva Best Security, Inc., et al.

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1751-S

Plaintiff Diby Ako’s First Set of Discovery

to Defendant Arriva Best Security, Inc.

IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

DIBY AKO PLAINTIFF

vs. No. 3:22-cv-1751-S

ARRIVA BEST SECURITY, INC., DEFENDANTS

and AMOIFO KOFFI

PLAINTIFF DIBY AKO’S FIRST SET OF

WRITTEN DISCOVERY TO DEFENDANT ARRIVA BEST SECURITY, INC.

Plaintiff Diby Ako (“Plaintiff”), by and through his attorney Josh Sanford of Sanford 

Law Firm, PLLC, and for his First Set of Interrogatories, Request for Production, and 

Requests for Admission to Separate Defendant Arriva Best Security, Inc. (“Defendant”),

pursuant to Rules 33, 34, and 36 of the Federal Rules of Civil Procedure, to be answered 

within thirty days after service of this request, does hereby state as follows:

I. GENERAL INSTRUCTIONS AND DEFINITIONS

1. Each answer shall be made separately, fully in writing, and should be 

provided by delivering or mailing them to the offices of Sanford Law Firm, PLLC, 

Kirkpatrick Plaza, 10800 Financial Centre Pkwy, Suite 510, Little Rock, Arkansas 72211, 

or if sent via email, to sean@sanfordlawfirm.com and josh@sanfordlawfirm.com.

2. These requests are continuing in nature for all information that is now or 

may hereafter become known or available to Defendants until the date of compliance with 

this request or trial, whichever is later, unless otherwise stated. Defendant should respond 

Case 3:22-cv-01751-S Document 41-1 Filed 12/02/24 Page 1 of 5 PageID 233
Page 2 of 4

Diby Ako v. Arriva Best Security, Inc., et al.

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1751-S

Plaintiff Diby Ako’s First Set of Discovery

to Defendant Arriva Best Security, Inc.

with additional information subsequent to its initial responses as and whenever such 

additional information is acquired, located, or comes into existence.

3. If you must qualify a response or deny only a part of the matter to which an 

admission is requested, specify so much of the request as is true and qualify or deny the 

remainder.

4. “Plaintiff” refers to Diby Ako.

5. The terms “you,” “your,” “yours,” and “Defendant” are intended to mean 

Arriva Best Security, Inc., unless otherwise specifically indicated.

6. The conjunctions “and” and “or” shall be interpreted to mean “and/or,” and 

shall not be interpreted to exclude any information otherwise within the scope of any 

request.

II. PLAINTIFF’S INTERROGATORIES AND REQUESTS FOR PRODUCTION TO 

DEFENDANT ARRIVA BEST SECURITY, INC.

INTERROGATORY NO. 1. State Defendant’s annual gross volume of sales made 

or business done for each of the three calendar years preceding the filing of this lawsuit.

REQUEST FOR PRODUCTION NO. 1. If Defendant contends that its annual 

gross volume of sales made or business done for any of the three calendar years 

preceding the filing of this lawsuit was less than $500,000.00, for each such year, produce 

true copies of all documents and tangible things relating to Interrogatory No. 1, including, 

but not limited to: (1) tax filings and returns for each of the three calendar years preceding 

the filing of this lawsuit; (2) balance sheets or statements of financial position, which show 

Defendant’s assets, liabilities, and ownership equity at any point in each of the three 

calendar years preceding the filing of this lawsuit; (3) income statements for each of the 

Case 3:22-cv-01751-S Document 41-1 Filed 12/02/24 Page 2 of 5 PageID 234
Page 3 of 4

Diby Ako v. Arriva Best Security, Inc., et al.

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1751-S

Plaintiff Diby Ako’s First Set of Discovery

to Defendant Arriva Best Security, Inc.

three calendar years preceding the filing of this lawsuit, and “income statements” means 

statements of comprehensive income, statements of revenue and expense, P&L, profit 

and loss reports, revenue statements, statements of financial performance, earnings 

statements, operating statements, statements of operations, or statements of cash flows, 

which show Defendant’s revenues and expenses; (4) loan applications made by 

Defendant during all of the three calendar years preceding the filing of this lawsuit; and 

(5) cash flow statements or statements of cash flows for each of the three calendar years 

preceding the filing of this lawsuit, and “cash flow statements” means financial statements 

that show how changes in balance sheet accounts and income affect cash and cash 

equivalents, and breaks the analysis down to operating, investing and financing activities, 

or in other words, shows the flow of cash in and out of the business; (6) account 

statements from bank accounts owned by Defendant at any time during the three years 

preceding the filing of this lawsuit; and (7) financial statements for each of the three 

calendar years preceding the filing of this lawsuit, and “financial statements” means a 

formal record of the financial activities of a business.

INTERROGATORY NO. 2. State the types of security services Defendant provides 

and the city and state in which Defendant has provided these services in the three years 

preceding the filing of this lawsuit.

REQUEST FOR PRODUCTION NO. 2. Produce true copies of all documents and 

things showing the city and state of residence of each and every individual or company 

for which Defendant provided security services, the method by which each and every 

guest booked their room or rooms, and the dates for which each and every guest booked 

their room or rooms, during all times in which Plaintiff was employed with Defendant.

Case 3:22-cv-01751-S Document 41-1 Filed 12/02/24 Page 3 of 5 PageID 235
Page 4 of 4

Diby Ako v. Arriva Best Security, Inc., et al.

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1751-S

Plaintiff Diby Ako’s First Set of Discovery

to Defendant Arriva Best Security, Inc.

INTERROGATORY NO. 3. Identify each and every state and country in which 

Defendant advertised its services, and identify each and every medium of advertisement 

and the name of any publication or publisher for each state and country, from six years 

prior to Plaintiff’s start date through the end of Plaintiff’s employment with Defendant.

III. PLAINTIFF’S REQUESTS FOR ADMISSIONS TO 

DEFENDANT ARRIVA BEST SECURITY, INC.

REQUEST FOR ADMISSION NO. 1. Admit that Defendant’s annual gross 

volume of sales made or business done has been greater than $500,000.00 for each of 

the three calendar years preceding the filing of this lawsuit.

REQUEST FOR ADMISSION NO. 2. Admit that Defendant has two or more 

employees engaged in security services.

REQUEST FOR ADMISSION NO. 3. Admit that Defendant provides security 

services in all 50 states.

REQUEST FOR ADMISSION NO. 4. Admit that Defendant provides security 

services for athletic events attended by persons who reside outside of the state in which 

the event takes place.

REQUEST FOR ADMISSION NO. 5. Admit that Defendant regularly contacts 

employees across state lines to direct their duties and give assignments.

Case 3:22-cv-01751-S Document 41-1 Filed 12/02/24 Page 4 of 5 PageID 236
Page 5 of 4

Diby Ako v. Arriva Best Security, Inc., et al.

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1751-S

Plaintiff Diby Ako’s First Set of Discovery

to Defendant Arriva Best Security, Inc.

Respectfully submitted,

PLAINTIFF DIBY AKO

SANFORD LAW FIRM, PLLC

Kirkpatrick Plaza

10800 Financial Centre Pkwy, Suite 510

Little Rock, Arkansas 72211

Telephone: (800) 615-4946

Facsimile: (888) 787-2040

/s/ Josh Sanford

Josh Sanford

Tex. Bar No. 24077858

josh@sanfordlawfirm.com

CERTIFICATE OF SERVICE

I, Josh Sanford, do hereby certify that on December ___, 2024, a true and correct 

copy of the foregoing discovery was sent via U.S. Mail and electronic mail to the pro se

party named below:

Arriva Best Security Inc.

c/o Aimee Koffee

5482 Wilshire Blvd. Ste. 219

Los Angeles, CA 90036

Amoifo Koffee

9955 Durant Drive, Unit 304

Beverley Hills, CA 90212-1601

Arriva Best Security Inc.

2435 N. Central Express Way, 12th Floor

Richardson, Texas 75080

/s/ Josh Sanford 

Josh Sanford 

Case 3:22-cv-01751-S Document 41-1 Filed 12/02/24 Page 5 of 5 PageID 237