FRCP 36 –RESPONSES 15-00907 Page 1 of 4

Carl D. Crowell, OSB No. 982049

carl@crowell-law.com

CROWELL LAW

P.O. Box 923

Salem, OR 97308

(503) 581-1240

Of attorneys for Plaintiff

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

DALLAS BUYERS CLUB, LLC, 

 Plaintiff,

vs.

JOHN HUSZAR,

 Defendant.

 Case No.:3:15-cv-00907-AC

Plaintiff’s Response to Defendant’s Requests 

for Admissions

Requests (#1–9)

FRCP 36

Nos. 1 - 9

Pursuant to and in accordance with the rules and standards of the Federal Rules of Civil 

Procedure and related Local Rules, in particular FRCP 26 and 36, and the Order of this Court on 

further discovery, Dallas Buyers Club, LLC responds to Defendant’s submitted Requests for 

Admissions (Nos. 1-9) as follows:

General Objection

Plaintiff objects to any instruction that deviates or alters its obligations under convention, 

the Federal Rules of Civil Procedure and related Local Rules and responds solely as it may elect 

to do so voluntarily or as required pursuant to such rules and as Plaintiff understands and 

interprets the submitted requests. Plaintiff also objects to atypical language that creates obscure 

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 1 of 14
FRCP 36 –RESPONSES 15-00907 Page 2 of 4

or misleading answers and directs that requests should be submitted in plain, specific and 

coherent language.

DEFENDANT’S REQUESTS FOR ADMISSION

1. Admit the Genuineness of the nine documents attached as Exhibit A.

RESPONSE: Plaintiff objects to the vague term “Genuineness” but ADMITS that the 

documents of Exhibit A appear to be copies of original documents in used in various 

proceedings and of record with various courts, except it is noted there are a number of pages 

missing from what appears in the original documents and several pages are duplicated.

2. Admit that the Subject Hash is identical in Exhibits A-1, A-5 at page 14, A-6 at pages 

16-18, A-7 at page 4, A-8 at page 8, and A-9 at page 10.

RESPONSE: Plaintiff objects as this request is vague and confusing but confirms the HASH 

F18A60DB02EC3B55C18924F47955DE766DACC537 appears multiple times, including in 

Exhibit A-1. The HASH does not seems to appear at A-5, p14. The HASH does appear on A6, p. 16-18, A-7, p. 4, A-8, p. 8, and A-9 at page 10.

3. Admit Your Infringement Detection system does not monitor the Tor Protocol.

RESPONSE: Plaintiff objects as this request is vague and misleading. Plaintiff admits that the 

neither the Excipio investigative tool nor the MavickMonitor tool independently monitor the Tor 

Protocol, but do monitors BitTorrent activity, whether or not it occurs through the Tor Protocol 

sub-set.

4. Admit that the infringement alleged in the SAC did not go through the Tor Network.

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 2 of 14
FRCP 36 –RESPONSES 15-00907 Page 3 of 4

RESPONSE: Plaintiff objects as the allegations related to use of the Tor Network are those

raised by the Defendant, not Plaintiff. Plaintiff is without sufficient facts to either admit or deny 

this claim and so has plead in the alternative. FRCP 8(d).

5. Admit that MaverickEye UG is the only entity that monitored Defendant’s IP Address in 

relation to the infringement alleged in the SAC.

RESPONSE: DENY

6. Admit that MaverickEye UG is the only entity that captured the Observed Data in 

relation to the infringement alleged in the SAC.

RESPONSE: DENY

7. Admit that Your method for detecting infringements is not 100% accurate. 

RESPONSE: Plaintiff objects as this request is vague, but DENIES. It is presumed as an 

axiomatic principal that no system outside of the divine constructs of God are without error or

100% accurate, but to date there are no known errors in detection of infringing activity 

associated with an IP Address through the MavrickMonitor system.

8. Admit that an IP Address cannot be used to identify a person with absolute certainty. 

RESPONSE: ADMIT

9. Admit that Defendant’s WIFI signal extends beyond the legal boundary of his house. 

RESPONSE: Plaintiff has no evidence that a Wi-Fi signal was ever used at the Defendant’s 

house, or any information about legal boundaries and therefore cannot admit or deny this request. 

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 3 of 14
FRCP 36 –RESPONSES 15-00907 Page 4 of 4

= = = =

CERTIFICATE OF SERVICE

I certify that the foregoing document is being served on the date indicated below by 

transmitting a copy thereof by electronic mail to defendant as follows:

Michael O. Stevens 

STEVENS & LEGAL, LLC

3699 NW John Olsen Place

Hillsboro, OR 97124

email: michael@hillsborofirm.com

DATED this 22nd day of April, 2016.

Crowell Law

/s/ Carl D. Crowell

Carl D. Crowell, OSB# 982049

P.O. Box 923

Salem, OR 97308

503-581-1240

carl@crowell-law.com

Of Attorneys for Plaintiff

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 4 of 14
FRCP 36 –RESPONSES 15-00907 – Set 2 Page 1 of 2

Carl D. Crowell, OSB No. 982049

carl@crowell-law.com

CROWELL LAW

P.O. Box 923

Salem, OR 97308

(503) 581-1240

Of attorneys for Plaintiff

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

DALLAS BUYERS CLUB, LLC, 

 Plaintiff,

vs.

JOHN HUSZAR,

 Defendant.

 Case No.:3:15-cv-00907-AC

Plaintiff’s Response to Defendant’s Requests 

for Admissions

Request (#10)

FRCP 36

No. 10

Pursuant to and in accordance with the rules and standards of the Federal Rules of Civil 

Procedure and related Local Rules, in particular FRCP 26 and 36, and the Order of this Court on 

further discovery, Dallas Buyers Club, LLC responds to Defendant’s submitted Requests for 

Admission Nos. 10 as follows:

General Objection

Plaintiff objects to any instruction that deviates or alters its obligations under convention, 

the Federal Rules of Civil Procedure and related Local Rules and responds solely as it may elect 

to do so voluntarily or as required pursuant to such rules and as Plaintiff understands and 

interprets the submitted requests. Plaintiff also objects to atypical language that creates obscure 

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 5 of 14
FRCP 36 –RESPONSES 15-00907 – Set 2 Page 2 of 2

or misleading answers and directs that requests should be submitted in plain, specific and 

coherent language.

DEFENDANT’S REQUESTS FOR ADMISSION

10. Admit the only Film You claim Defendant infringed is the Work.

RESPONSE: DENY.

= = = =

CERTIFICATE OF SERVICE

I certify that the foregoing document is being served on the date indicated below by 

transmitting a copy thereof by electronic mail to defendant as follows:

Michael O. Stevens 

STEVENS & LEGAL, LLC

3699 NW John Olsen Place

Hillsboro, OR 97124

email: michael@hillsborofirm.com

DATED this 25th day of June, 2017.

Crowell Law

/s/ Carl D. Crowell

Carl D. Crowell, OSB# 982049

P.O. Box 923

Salem, OR 97308

503-581-1240

carl@crowell-law.com

Of Attorneys for Plaintiff

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 6 of 14
FRCP 36 –RESPONSES 15-00907 – SET 3 Page 1 of 4

Carl D. Crowell, OSB No. 982049

carl@crowell-law.com

CROWELL LAW

P.O. Box 923

Salem, OR 97308

(503) 581-1240

Of attorneys for Plaintiff

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

DALLAS BUYERS CLUB, LLC, 

 Plaintiff,

vs.

JOHN HUSZAR,

 Defendant.

 Case No.:3:15-cv-00907-AC

Plaintiff’s Response to Defendant’s Requests 

for Admissions

Requests (#11–20)

FRCP 36

SET 3 : Nos. 11-20

Pursuant to and in accordance with the rules and standards of the Federal Rules of Civil 

Procedure and related Local Rules, in particular FRCP 26 and 36, and the Order of this Court on 

further discovery, Dallas Buyers Club, LLC responds to Defendant’s submitted Requests for 

Admissions (Nos. 11-20) as follows:

General Objection

Plaintiff objects to any instruction that deviates or alters its obligations under convention, 

the Federal Rules of Civil Procedure and related Local Rules and responds solely as it may elect 

to do so voluntarily or as required pursuant to such rules and as Plaintiff understands and 

interprets the submitted requests. Plaintiff also objects to atypical language that creates obscure 

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 7 of 14
FRCP 36 –RESPONSES 15-00907 – SET 3 Page 2 of 4

or misleading answers and directs that requests should be submitted in plain, specific and 

coherent language.

DEFENDANT’S REQUESTS FOR ADMISSION

11. Admit to Genuineness of Exhibit A.

RESPONSE: Plaintiff objects to the vague term “Genuineness” but ADMITS that the 

document of Exhibit A appears to be a true copy of document obtained through the PACER 

system. 

12. Admit to Genuineness of Exhibit B.

RESPONSE: Plaintiff objects to the vague term “Genuineness” but ADMITS that the 

documents of Exhibit B appear to be true copies of documents obtained through the PACER 

system. 

13. Admit to Genuineness of Exhibit C.

RESPONSE: Plaintiff objects to the vague term “Genuineness” but ADMITS that the 

document of Exhibit C appears to be a true copy of document obtained through the PACER 

system. 

14. Admit to Genuineness of Exhibit D.

RESPONSE: Plaintiff objects to the vague term “Genuineness” but ADMITS that the 

document of Exhibit D appears to be a true copy of document obtained through the PACER 

system. 

15. Admit to Genuineness of Exhibit E.

RESPONSE: Plaintiff objects to the vague term “Genuineness” but ADMITS that the 

document of Exhibit E appears to be a true copy of document obtained through the PACER 

system. 

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 8 of 14
FRCP 36 –RESPONSES 15-00907 – SET 3 Page 3 of 4

16. Admit to Genuineness of Exhibit F.

RESPONSE: Plaintiff objects to the vague term “Genuineness” but ADMITS that the 

document of Exhibit F appears to be a true copy of document obtained through the PACER 

system. 

17. Admit to Genuineness of Exhibit G.

RESPONSE: Plaintiff objects to the vague term “Genuineness” but ADMITS that the 

documents of Exhibit G appear to be true copies of documents obtained through the PACER 

system. 

18. Admit to Genuineness of Exhibit H.

RESPONSE: Plaintiff objects to the vague term “Genuineness.” Plaintiff has no knowledge of 

the authenticity of the documents of Exhibit H, but admits it does not have any reason to doubt 

authenticity of the relevant documents. 

19. Admit to Genuineness of Exhibit I.

RESPONSE: Plaintiff objects to the vague term “Genuineness.” Plaintiff has no knowledge of 

the authenticity of the document of Exhibit I, but admits it does not have any reason to doubt 

authenticity of the relevant document. 

20. Admit to Genuineness of Exhibit J.

RESPONSE: Plaintiff objects to the vague term “Genuineness.” Plaintiff has no knowledge of 

the authenticity of the documents of Exhibit J, but admits it does not have any reason to doubt 

authenticity of the relevant documents. 

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 9 of 14
FRCP 36 –RESPONSES 15-00907 – SET 3 Page 4 of 4

= = = =

CERTIFICATE OF SERVICE

I certify that the foregoing document is being served on the date indicated below by 

transmitting a copy thereof by electronic mail to defendant as follows:

Michael O. Stevens 

STEVENS & LEGAL, LLC

3699 NW John Olsen Place

Hillsboro, OR 97124

email: michael@hillsborofirm.com

DATED this 20th day of July, 2017.

Crowell Law

/s/ Carl D. Crowell

Carl D. Crowell, OSB# 982049

P.O. Box 923

Salem, OR 97308

503-581-1240

carl@crowell-law.com

Of Attorneys for Plaintiff

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 10 of 14
FRCP 36 –RESPONSES 15-00907 SET 4: Nos. 21 - 40 Page 1 of 4

Carl D. Crowell, OSB No. 982049

carl@crowell-law.com

CROWELL LAW

P.O. Box 923

Salem, OR 97308

(503) 581-1240

Of attorneys for Plaintiff

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

DALLAS BUYERS CLUB, LLC, 

 Plaintiff,

vs.

JOHN HUSZAR,

 Defendant.

 Case No.:3:15-cv-00907-AC

Plaintiff’s Response to Defendant’s Requests 

for Admissions

Requests (#21-40)

FRCP 36

SET FOUR

Pursuant to and in accordance with the rules and standards of the Federal Rules of Civil 

Procedure and related Local Rules, in particular FRCP 26 and 36, and the Order of this Court on 

further discovery, Dallas Buyers Club, LLC responds to Defendant’s submitted Requests for 

Admissions (Nos. 21-40) as follows:

General Objection

Plaintiff objects to any instruction that deviates or alters its obligations under convention, 

the Federal Rules of Civil Procedure and related Local Rules and responds solely as it may elect 

to do so voluntarily or as required pursuant to such rules and as Plaintiff understands and 

interprets the submitted requests. Plaintiff also objects to atypical language that creates obscure 

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 11 of 14
FRCP 36 –RESPONSES 15-00907 SET 4: Nos. 21 - 40 Page 2 of 4

or misleading answers and directs that requests should be submitted in plain, specific and 

coherent language.

DEFENDANT’S REQUESTS FOR ADMISSION

21. Admit the case in Exhibits A-C involves the same Plaintiff as this case.

RESPONSE: ADMIT

22. Admit the case in Exhibits A-C involves the same Work as this case.

RESPONSE: ADMIT

23. Admit the case in Exhibits A-C involves the same Subject Hash as this case.

RESPONSE: ADMIT

24. Admit in the case in Exhibits A-C, DBC used Forensic Software to monitor the Subject 

Hash.

RESPONSE: Objection as to being vague, DENY

25. Admit for the case in Exhibits A-C, DBC used Forensic Software to scan peer-to-peer 

networks for the presence of infringing transactions with respect to the Work.

RESPONSE: Objection as to being vague, DENY

26. Admit in the case in Exhibits A-C, DBC used Forensic Software to identify the IP 

addresses being used by people using the BitTorrent protocol and internet to infringe the 

Work.

RESPONSE: Objection as to being vague, DENY

27. Admit the case in Exhibits D-E involves the same Plaintiff as this case.

RESPONSE: ADMIT

28. Admit the case in Exhibits D-E involves the same Work as this case.

RESPONSE: ADMIT

29. Admit the case in Exhibits D-E involves the same Subject Hash as this case.

RESPONSE: ADMIT

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 12 of 14
FRCP 36 –RESPONSES 15-00907 SET 4: Nos. 21 - 40 Page 3 of 4

30. Admit in the case in Exhibits D-E, Crystal Bay Corporation used Forensic Software to 

monitor the Subject Hash.

RESPONSE: ADMIT

31. Admit in the case in Exhibits D-E, Crystal Bay Corporation used Forensic Software to 

scan peer-to-peer networks for the presence of transactions infringing the Work.

RESPONSE: ADMIT

32. Admit in the case in Exhibits D-E, Crystal Bay Corporation used Forensic Software to 

identify the IP addresses being used by people using the BitTorrent protocol and internet 

to infringe the Work.

RESPONSE: ADMIT

33. Admit the case in Exhibits F-G involves the same Plaintiff as this case.

RESPONSE: ADMIT

34. Admit the case in Exhibits F-G involves the same Work as this case.

RESPONSE: ADMIT

35. Admit the case in Exhibits F-G involves the same Subject Hash as this case.

RESPONSE: ADMIT

36. Admit in the case in Exhibits F-G, Crystal Bay Corporation used Forensic Software to 

monitor the Subject Hash.

RESPONSE: ADMIT

37. Admit in the case in Exhibits F-G, Crystal Bay Corporation used Forensic Software to 

scan peer-to-peer networks for the presence of transactions infringing the Work.

RESPONSE: ADMIT

38. Admit in the case in Exhibits F-G, Crystal Bay Corporation used Forensic Software to 

identify the IP addresses being used by people using the BitTorrent protocol and internet 

to infringe the Work.

RESPONSE: ADMIT

39. Admit Crystal Bay Corporation is incorporated in South Dakota.

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 13 of 14
FRCP 36 –RESPONSES 15-00907 SET 4: Nos. 21 - 40 Page 4 of 4

RESPONSE: Objection as to vague, DENY. On information and belief Crystal Bay is 

no longer in business.

40. Admit Crystal Bay Corporation’s principle place of business is in South Dakota.

RESPONSE: Objection as to vague, DENY. On information and belief Crystal Bay is 

no longer in business.

= = = =

CERTIFICATE OF SERVICE

I certify that the foregoing document is being served on the date indicated below by 

transmitting a copy thereof by electronic mail to defendant as follows:

Michael O. Stevens 

STEVENS & LEGAL, LLC

3699 NW John Olsen Place

Hillsboro, OR 97124

email: michael@hillsborofirm.com

DATED this 20th day of July, 2016.

Crowell Law

/s/ Carl D. Crowell

Carl D. Crowell, OSB# 982049

P.O. Box 923

Salem, OR 97308

503-581-1240

carl@crowell-law.com

Of Attorneys for Plaintiff

Case 3:15-cv-00907-AC Document 138-5 Filed 02/28/18 Page 14 of 14