EXHIBIT A

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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT

for the

__________ District of __________

)

)

)

)

)

)

Plaintiff

v. Civil Action No.

Defendant

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION 

To:

(Name of person to whom this subpoena is directed)

’ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following 

documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the

material:

Place: Date and Time:

’ Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or 

other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party

may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

Place: Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;

Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to

respond to this subpoena and the potential consequences of not doing so.

Date:

CLERK OF COURT

OR

Signature of Clerk or Deputy Clerk Attorney’s signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)

, who issues or requests this subpoena, are:

Notice to the person who issues or requests this subpoena

If this subpoena commands the production of documents, electronically stored information, or tangible things or the

inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before

it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE

(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)

I received this subpoena for (name of individual and title, if any)

on (date) .

’ I served the subpoena by delivering a copy to the named person as follows:

on (date) ; or

’ I returned the subpoena unexecuted because:

.

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also 

tendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of

$ .

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:

Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc.:

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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action(Page 3)

Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)

(c) Place of Compliance.

 (1) For a Trial, Hearing, or Deposition. A subpoena may command a

person to attend a trial, hearing, or deposition only as follows:

 (A) within 100 miles of where the person resides, is employed, or

regularly transacts business in person; or

 (B) within the state where the person resides, is employed, or regularly

transacts business in person, if the person

 (i) is a party or a party’s officer; or

 (ii) is commanded to attend a trial and would not incur substantial

expense.

 (2) For Other Discovery. A subpoena may command:

 (A) production of documents, electronically stored information, or

tangible things at a place within 100 miles of where the person resides, is

employed, or regularly transacts business in person; and

 (B) inspection of premises at the premises to be inspected.

(d) Protecting a Person Subject to a Subpoena; Enforcement.

 (1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney

responsible for issuing and serving a subpoena must take reasonable steps

to avoid imposing undue burden or expense on a person subject to the

subpoena. The court for the district where compliance is required must

enforce this duty and impose an appropriate sanction—which may include

lost earnings and reasonable attorney’s fees—on a party or attorney who

fails to comply.

 (2) Command to Produce Materials or Permit Inspection.

 (A) Appearance Not Required. A person commanded to produce

documents, electronically stored information, or tangible things, or to

permit the inspection of premises, need not appear in person at the place of

production or inspection unless also commanded to appear for a deposition,

hearing, or trial.

 (B) Objections. A person commanded to produce documents or tangible

things or to permit inspection may serve on the party or attorney designated

in the subpoena a written objection to inspecting, copying, testing, or

sampling any or all of the materials or to inspecting the premises—or to

producing electronically stored information in the form or forms requested.

The objection must be served before the earlier of the time specified for

compliance or 14 days after the subpoena is served. If an objection is made,

the following rules apply:

 (i) At any time, on notice to the commanded person, the serving party

may move the court for the district where compliance is required for an

order compelling production or inspection.

 (ii) These acts may be required only as directed in the order, and the

order must protect a person who is neither a party nor a party’s officer from

significant expense resulting from compliance.

 (3) Quashing or Modifying a Subpoena.

 (A) When Required. On timely motion, the court for the district where

compliance is required must quash or modify a subpoena that:

 (i) fails to allow a reasonable time to comply;

 (ii) requires a person to comply beyond the geographical limits

specified in Rule 45(c);

 (iii) requires disclosure of privileged or other protected matter, if no

exception or waiver applies; or

 (iv) subjects a person to undue burden.

 (B) When Permitted. To protect a person subject to or affected by a

subpoena, the court for the district where compliance is required may, on

motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research,

development, or commercial information; or

 (ii) disclosing an unretained expert’s opinion or information that does

not describe specific occurrences in dispute and results from the expert’s

study that was not requested by a party.

 (C) Specifying Conditions as an Alternative. In the circumstances

described in Rule 45(d)(3)(B), the court may, instead of quashing or

modifying a subpoena, order appearance or production under specified

conditions if the serving party:

 (i) shows a substantial need for the testimony or material that cannot be

otherwise met without undue hardship; and

 (ii) ensures that the subpoenaed person will be reasonably compensated.

(e) Duties in Responding to a Subpoena.

 (1) Producing Documents or Electronically Stored Information. These

procedures apply to producing documents or electronically stored

information:

 (A) Documents. A person responding to a subpoena to produce documents

must produce them as they are kept in the ordinary course of business or

must organize and label them to correspond to the categories in the demand.

 (B) Form for Producing Electronically Stored Information Not Specified.

If a subpoena does not specify a form for producing electronically stored

information, the person responding must produce it in a form or forms in

which it is ordinarily maintained or in a reasonably usable form or forms.

 (C) Electronically Stored Information Produced in Only One Form. The

person responding need not produce the same electronically stored

information in more than one form.

 (D) Inaccessible Electronically Stored Information. The person

responding need not provide discovery of electronically stored information

from sources that the person identifies as not reasonably accessible because

of undue burden or cost. On motion to compel discovery or for a protective

order, the person responding must show that the information is not

reasonably accessible because of undue burden or cost. If that showing is

made, the court may nonetheless order discovery from such sources if the

requesting party shows good cause, considering the limitations of Rule

26(b)(2)(C). The court may specify conditions for the discovery.

(2) Claiming Privilege or Protection.

 (A) Information Withheld. A person withholding subpoenaed information

under a claim that it is privileged or subject to protection as trial-preparation

material must:

 (i) expressly make the claim; and

 (ii) describe the nature of the withheld documents, communications, or

tangible things in a manner that, without revealing information itself

privileged or protected, will enable the parties to assess the claim.

 (B) Information Produced. If information produced in response to a

subpoena is subject to a claim of privilege or of protection as

trial-preparation material, the person making the claim may notify any party

that received the information of the claim and the basis for it. After being

notified, a party must promptly return, sequester, or destroy the specified

information and any copies it has; must not use or disclose the information

until the claim is resolved; must take reasonable steps to retrieve the

information if the party disclosed it before being notified; and may promptly

present the information under seal to the court for the district where

compliance is required for a determination of the claim. The person who

produced the information must preserve the information until the claim is

resolved.

(g) Contempt.

The court for the district where compliance is required—and also, after a

motion is transferred, the issuing court—may hold in contempt a person

who, having been served, fails without adequate excuse to obey the

subpoena or an order related to it.

For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).

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RESPONSE TO SUBPOENA

JASON M. SKAGGS (CA BAR NO. 202190)

JEFFREY E. FAUCETTE (CA BAR NO. 193066)

SKAGGS FAUCETTE LLP

Email: jason@skaggsfaucette.com

Email: jeff@skaggsfaucette.com

530 Lytton Avenue, 2nd Floor

Palo Alto, CA 94301

Telephone: 650/617-3226

Facsimile: 650/644-0200

Attorneys for LINKEDIN CORPORATION

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

WAYNE FARMS, LLC,

Plaintiff,

v.

JANE DOE AND LINKEDIN CORPORATION,

Defendants.

 Case No. 20-5191

LINKEDIN CORPORATION’S RESPONSE 

AND OBJECTIONS TO SUBPOENA 

ISSUED BY PLAINTIFF WAYNE FARMS 

LLC

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RESPONSE TO SUBPOENA

PROPOUNDING PARTY: WAYNE FARMS LLC

RESPONDING PARTY: LINKEDIN CORPORATION

LinkedIn Corporation (“LinkedIn”), hereby objects and responds to the subpoena 

(“Subpoena”) served by the attorney for Plaintiff Wayne Farms LLC(“Plaintiff”) responses and 

objections are based on its current understanding of the lawsuit and the Subpoena. LinkedIn reserves 

the right to modify or supplement its responses and objections. LinkedIn also reserves the right to 

make any motion with respect to the Subpoena. 

GENERAL OBJECTIONS

1. LinkedIn objects to the Subpoena to the extent that it seeks the production of 

information from sources that are not reasonably accessible because of undue burden or cost or 

otherwise. 

2. LinkedIn objects to the Subpoena to the extent it seeks information that is available 

from the parties to the litigation or other sources.

3. LinkedIn objects to the Subpoena to the extent it is intended to impose any 

obligations on any persons or entities other than LinkedIn, the sole entity named in the Subpoena, 

including but not limited to subsidiaries or affiliates of LinkedIn. 

4. LinkedIn objects to the Subpoena to the extent it requests the production of 

information beyond the possession, custody or control of LinkedIn. 

5. LinkedIn objects to the Subpoena to the extent that it seeks information protected 

by the attorney-client privilege, the attorney work product doctrine, or any other applicable privilege 

or protection from discovery under the California Code of Civil Procedure, the California Evidence 

Code, the California Family Code, and/or any other applicable statutes, regulations, and common law 

protections. LinkedIn intends to claim and hereby claims all applicable privileges and protections 

from discovery, and, in the event that LinkedIn provides responsive documents, any mistaken or 

inadvertent production of privileged or protected documents is not intended to, and shall not, waive 

any of these privileges or protections. LinkedIn is not presently in a position to provide a description 

of the nature of the information that is subject to a claim of privilege or protection. In the event the 

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RESPONSE TO SUBPOENA

Subpoena is found valid and enforceable, in whole or in part, LinkedIn will provide such a description 

within a reasonable period of time.

6. LinkedIn objects to the Subpoena to the extent it seeks trade secrets or other 

confidential research, development, or commercial information, or other proprietary information 

protected from disclosure.

7. LinkedIn objects to the Subpoena to the extent that it seeks information that is not 

reasonably calculated to lead to the discovery of admissible evidence. 

8. LinkedIn objects to the Subpoena as overbroad and unduly burdensome.

9. LinkedIn objects to Subpoena to the extent it seeks to impose obligations beyond or 

inconsistent with those imposed by the applicable California statutes.

RESPONSES TO REQUEST FOR DOCUMENTS

REQUEST FOR PRODUCTION NO. 1:

All documents and information relating JOHN DOE with a fake LinkedIn profile as an 

employee of Wayne Farms LLC or Wayne Farms LLC USA, Phone text, WhatsApp or mobile 

number: +1(204) 813-6903 or +1 (323) 486-5804; Email patrickwaynefarms@consultant.com or 

patrickwaynefarms@outlook.com (see attached)

RESPONSE TO REQUEST FOR PRODUCTION NO. 1:

In addition to its general objections, each of which is specifically incorporated herein by 

reference, LinkedIn objects to this request as vague and ambiguous with respect to the scope of the 

information sought and the manner or production, and in particular the terms “all documents and 

information” which may seek information protected by privacy rights and other protections. LinkedIn 

also objects to the Request to the extent it requests the production of documents beyond the possession, 

custody or control of LinkedIn. For example, LinkedIn does not have members’ social security 

numbers, telephone connection records, or MAC addresses. LinkedIn also objects to the Request to 

the extent that it seeks the content of communications and investigations. Production of records 

beyond basic subscriber information as defined at 18 U.S.C. § 2703(c)(2) without the consent of the 

LinkedIn member would exceed the disclosure permitted under the Stored Communications Act, 18 

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RESPONSE TO SUBPOENA

U.S.C. §§ 2702-03 (“SCA"). Under the SCA, LinkedIn is prohibited from disclosing the connections 

or content of user communications or stored files, unless a specific statutory exception permits the 

disclosure. 18 U.S.C. §§ 2702-2703. There is no general statutory exception that would allow 

LinkedIn to produce contents in response to your Request. LinkedIn reserves the right to add 

objections if necessary following any meet and confer.

Subject to, and without waiving these objections, LinkedIn will provide the following

information associated with the profile associated with each of the two email addresses identified as 

well as the Patrick Gomez profile identified (Wisconsin, United States): 

• Email Addresses 

• Profile Snapshot 

• Profile Information 

• Registration 

LinkedIn considers this information to be fully responsive to the Request and to have satisfied 

LinkedIn’s entire obligation in responding to the Subpoena.

DATED: October __, 2020. SKAGGS FAUCETTE LLP

By:

JASON M. SKAGGS

Attorneys for LINKEDIN CORPORATION.

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LINKEDIN-WF-000001

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LINKEDIN-WF-000002

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Gomez_Registration.csv

Registered At Registration Ip Subscription Types

6/16/20, 12:51 AM 45.82.254.20

LINKEDIN-WF-000003

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Gomez_Logins.csv

Login Date IP Address User Agent Login Type

Tue Jun 23 02:28:34 UTC 2020 66.115.157.13 LIAuthLibrary:36.0.* com.linkedin.LinkedIn:9.15.5204.4 iPhone:12.4.5 Login

Wed Jul 22 08:29:51 UTC 2020 156.146.46.65 LIAuthLibrary:36.0.* com.linkedin.LinkedIn:9.15.5204.4 iPhone:12.4.5 Login

LINKEDIN-WF-000004

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Gomez_Email Addresses.csv

Email Address Confirmed Primary Updated On

godsonnguyen101@gmail.com Yes Yes 6/16/20, 12:51 AM

butcherspride.frozenfoods@gmail.com No No 6/22/20, 7:27 PM

LINKEDIN-WF-000005

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Gomez_Profile csv

First Name Last Name

Maiden 

Name Address Birth Date Headline Summary Industry Zip Code

Geo 

Location

Twitter 

Handles Websites

Instant 

Messengers

Patrick Gomez

Export 

Manager at 

Wayne 

Farms

We are leading role 

model in food production 

and we export 

nationwide, our major 

products includes Frozen 

Foods such as Chicken 

Paw,Chicken Feet,Chicken 

MJW etc..... 

patrickwaynefarms@con

sultant com

Food 

Production

Wisconsin, 

United 

States

LINKEDIN-WF-000006

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LINKEDIN-WF-000007

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LINKEDIN-WF-000008

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Lincon_Registration.csv

Registered At Registration Ip Subscription Types

8/31/20, 6:28 AM 197.242.101.205

LINKEDIN-WF-000009

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Lincon_Logins.csv

Login Date IP Address User Agent Login Type

Mon Aug 31 16:05:13 UTC 2020 209.95.50.60 Mozilla/5.0 (iPhone; CPU iPhone OS 12_4_5 like Mac OS X) AppleWebKit/605.1.15 

(KHTML, like Gecko) Version/12.1.2 Mobile/15E148 Safari/604.1

Login

LINKEDIN-WF-000010

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Lincon_Email Addresses.csv

Email Address Confirmed Primary Updated On

patrickwaynefarms@outlook.com Yes Yes 8/31/20, 6:30 AM

LINKEDIN-WF-000011

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Lincon_Profile.csv

First Name Last Name

Maiden 

Name Address Birth Date Headline Summary Industry Zip Code

Geo 

Location

Twitter 

Handles Websites

Instant 

Messengers

Bright Lincon

Salesperson 

at Wayne 

Farms

Food 

Production 30018

Covington, 

Georgia, 

United 

States

LINKEDIN-WF-000012

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LINKEDIN-WF-000013

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Slessor_Registration.csv

Registered At Registration Ip Subscription Types

9/2/20, 5:05 AM 209.95.56.53

LINKEDIN-WF-000014

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Slessor_Logins.csv

Login Date IP Address User Agent Login Type

Wed Sep 02 13:44:54 UTC 2020 212.102.59.129

Mozilla/5.0 (iPhone; CPU iPhone OS 12_4_5 like Mac OS X) 

AppleWebKit/605.1.15 (KHTML, like Gecko) Version/12.1.2 

Mobile/15E148 Safari/604.1 Login

LINKEDIN-WF-000015

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Slessor_Email Addresses.csv

Email Address Confirmed Primary Updated On

patrickwaynefarms@consultant.com Yes Yes 9/2/20, 5:07 AM

LINKEDIN-WF-000016

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Slessor_Profile.csv

First Name Last Name

Maiden 

Name Address Birth Date Headline Summary Industry Zip Code Geo Location

Twitter 

Handles Websites

Instant 

Messengers

Tristan Slessor

Sales 

Manager at 

Best Buy Inc

Telecommun

ications 84101

Salt Lake 

City, Utah, 

United 

States

LINKEDIN-WF-000017

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